The Subscription Rooms Data Privacy Policy
The Subscription Rooms Trust is committed to being transparent in how we use your personal data and information, and how we protect your privacy rights. This policy aims to give you a clear explanation about how we use the information that we collect from you directly and through third parties. If you have any questions about our Data Protection policy, please email.
Who we are
The Subscription Rooms is managed by The Subscriptions Rooms Trust, and is owned by Stroud Town Council. This privacy policy refers to The Subscription Rooms Trust, as it is with The Subscription Rooms Trust that engaging with directly. Therefore your data is held with The Subscription Rooms Trust.
For the purposes of this privacy policy, Stroud Town Council is considered to be a third party organisation, and your data will only be shared in accordance to the ‘third party’ criteria as outlined below.
We do have a separate ‘Third Party Data Sharing policy for NPO Arts Organisations” which you can jump to here: The Sub Rooms Arts Data Sharing Agreement The Sub Rooms is a Charitable incorporated organisation (no. 1180350)
How do we collect your data
We collect your information in a number of different ways:
We will ONLY collect your personal sensitive data (eg. Health information, race, religious beliefs and political opinions) when there is CLEAR reason to do so.
1. Through the information that you give us
a. When you register on our website, buy tickets, join our membership schemes or make a donation, we will store the personal information that you give us including your name, email address, postal address, telephone number and card details.
b. We will also story a record of the purchases that you have made with us or any donations that you have made to support what we do.
2. Information about your interactions with us
a. We collect information about how you interact with our website, or content and show pages
b. We collect information when we send you a mailing. We record that mailings have been sent to you, and for the purposes of emails, we store a record of which emails you have opened and which links you have clicked on.
c. The above helps us to make sure that our communications with you are relevant and effective.
3. Sensitive personal data
a. We will collect your sensitive personal data if you attend accessible performances, or require special accessible provision. For example, if you attend an audio described performance, or book spaces for wheel chair users. This enables our Box Office system to unlock reserved seats in the appropriate areas of the auditorium. If you do not wish us to store this information about you, you may book your tickets by phone or in person, where will ensure that we make note of your requirements and do not assign it to your customer record.
b. We will collect your sensitive personal data for some workshops, food related events and participation classes. For example, if your workshop includes a light lunch we will record any food allergies that you may have. This information allows our workshop leaders and creative team to make any reasonable or necessary adjustments to creative classes for the individual. This information is stored in secure drives that are password protected.
How we process your information
There are three lawful bases under which we may process your data:
1. Contact purposes – We use the lawful basis of performance of a contract for the following:
a. Your purchase: When you make a purchase from us you are entering into a contract with The Subscription Rooms Trust. In order to perform this contract we need to process and store your data. We may occasionally need to contact you by email, letter or telephone about your purchase with us, such as in the case of a cancelled show, or should there be problems with your payment.
b. Joining our membership schemes – When you join Subscripton Rooms Trust membership scheme we may contact you by email, letter or telephone with information regarding your membership. This allows us to perform our contract with our members, providing the benefits that are promised. You have the right to object to any of this processing at any time. If you wish to object, please use the contact details provided at the end of this policy. However, if you object this may affect our ability to carry out tasks that are for your benefit
c. For any situation where contract purposes or legitimate organisational interest are not appropriate as a lawful basis for the processing of your data, we will instead ask for your consent before using your personal information in that specific situation. Situations when we use consent to process your data or contact you include
i. Sharing your data with another organisation: We may ask you if you would like your data to be shared with another organisation, such as a visiting theatre company or event organiser. We only do this if you give us your active consent.
ii. Group booking telephone calls: If you make group bookings for events at our theatre, we may ask you if you would like to be contacted by telephone about forthcoming shows.
iii. Fundraising information: We may ask you if you would like to receive news and information on fundraising and development initiatives undertaken by The Subscription Rooms Trust. You will be given the chance to opt out of these initiatives in every instance.
2. Legitimate Organisational Interest – In certain situations we may collect and process your personal information for purposes under the lawful basis of legitimate organisational interest. However, we only do this if there is no overriding prejudice to you caused by The Subscription Rooms Trust through using your personal information in this way. In these cases we will always keep your fundamental rights and freedoms at the forefront or what we do. We describe below all of the situations where we may use Legitimate Organisational Interest as the basis for processing your information, or contacting you.
a. Marketing communications – We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this, we use data that we have stored about you, such as information on which events you have booked for in the past, as well as any preferences you may have told us about. We use legitimate organisational interest as the legal basis for sending you marketing communications by post and email. Communications that we send to you may include relevant information about future shows and events, our membership schemes and regular newsletters about the theatre and its future productions.
i. Postal mailings: In the case of postal mailings, you can withdraw your consent to receive these mailings at any time by visiting our website or talking to a member of our Box Office team. You can also object to receiving these at any time by using the contact details provided at the end of this policy. However, we may still contact you by post for matters relating to your purchases (such as in the event of a cancelled performance or a problem with your payment).
ii. Email communications: In the case of email, we will give you an opportunity to opt out of receiving emails during your first purchase with us. If you do not opt out at that point, we will provide you with an option to unsubscribe in every email that we subsequently send you. You can withdraw your consent to receive emails at any time by visiting our website or by talking to a member of our Box Office team. You can also object to receiving these at any time by using the contact details provided at the end of this policy. However, we may still contact you by email for matters relating to your purchases (such as in the event of a cancelled performance or a problem with your payment).
iii. Telephone contact: We may contact you about our work by telephone however we will always get explicit consent from you before doing this. You can withdraw your consent to receive phone calls from us at any time by visiting our website or talking to a member of our Box Office team. You can also object to receiving these phone calls at any time by using the contact details provided at the end of this policy. However, we may still contact you by telephone for matters relating to your purchases (such as in the event of a cancelled performance or a problem with your payment
b. Analysis of communications – We may analyse data that we hold about you (such as past ticket purchase history) to help us ensure that the content and timing of communications that we send you by post or email are as relevant to you as possible.
c. Fraud prevention- We may analyse data we hold about you in order to identify and prevent fraud.
d. Analysis of our website – In order to improve our website, we may analyse information about how you use it and how you interact with the show pages and content that it contains.
e. Customer profiling. To allow us to understand more about who we attract to our events and activities we may undertake data analysis and profiling of our customer database. This provides us with generalised information on our audiences, helping us to understand the geographic and demographic trends of the people who participate in what we do.
Profiling helps us to understand which segments of our audience database should be targeted with information about a particular show or service offered by The Subscription Rooms Trust. This allows for our marketing to be more effective at giving the right information to the most relevant customers.
Profiling is undertaken for The Subscription Rooms Trust by third party organisations, including The Audience Agency and Purple Seven. This process involves The Subscription Rooms Trust securely sharing its customer data with these organisations. You have the right to object to this processing at any time. If you wish to object, please use the contact details provided at the end of this policy.
f. Customer surveys. To allow The Subscription Rooms Trust to understand what customers think about the quality of the service that it provides to them, we send daily surveys to customers who have attended our events.
These surveys may be undertaken and processed by a third party organisation, like Purple Seven or similar. This process involves The Subscription Rooms Trust securely sharing its data with this organisation. These surveys may include questions about gender, disability, occupation, ethnicity and age. This information is only used for anonymised and statistical purposes, allowing us to understand which audiences we do, and do not, attract. You are not required to supply this information and it is entirely optional as to whether you choose to do so.
The Subscription Rooms Trust may also send surveys to customers to help understand the quality of the service that it provides in other areas of its operation, including our Café Bar, membership schemes and creative classes. These surveys may be undertaken and processed by third party organisations. This process may involves The Subscription Rooms Trust securely sharing its data with these organisations for that purpose. If you would prefer not to be contacted in this way, please inform us by using the contact details provided below.
3). Third Parties There are certain circumstances under which we may disclose your personal information to third parties. These circumstances are:
a. To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software, mailing houses, telesales company, insight analysis providers). In these cases, we require that these third parties comply strictly with our instructions and with relevant data protection laws, for example around the security of personal data.
b. Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
c. To specific and named visiting theatre companies or event organisers whose performances or events you have attended.
i. Ammonised analysis information – we may share your behavioural data with third party arts organisations, so they improve their insight into how they are engaging with their audiences. In these cases, in these cases, your data will always be ammonised and will form part of co-hort statistics. For example “The Subscription Rooms Trust sold x number of tickets to this event”. In this instance the Third Party will have no means in order to contact you.
ii. We will only share your contact information with third party organisations if we have previously asked for your explicit consent before hand. We also require that these third parties comply strictly with our instructions and with relevant data protection laws, for example around the security of personal data.
iii. You can download a copy of our Third Party Arts Organisations Data Sharing Policy here, and can opt out of this at any time by logging into your account on our website, or contacting our Box Office, or using the contact details below.
Other data
Cookies
Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your online shopping basket) as well as to provide website operators with information on how the site is being used.
We use cookies to keep track of your basket, to identify how the website is being used and to help inform improvements to the overall customer experience that it offers.
You can opt out of Cookies during you website visit, by clicking the opt our button.
Debit and Credit Card Information
If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS).
We optionally allow you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.
Maintaining your personal information
We store your personal information for eight years so that, for any subsequent purchases you make, we are able to link them back to a single unique record that we hold for you on our system.
If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging into your account via the My Account section of our website. Alternatively, you can contact the Box Office team or use the contact details provided at the end of this policy.
Any objections that you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
Security of your personal information
We will put in place appropriate safeguards (both in terms of our procedures and the technology that we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
We will not usually transfer, process or store your data anywhere that is outside of the European Economic Area. However, if such processing does take place, The Subscription Rooms Trust will ensure that companies who undertake it adhere to the EU-U.S. Privacy Shield agreement
Your rights to your personal information
You have a right to request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected.
Please use the contact details provided at the end of this policy if you would like to exercise this right
Contact details and further information
Please get in touch with us via the contact details below if you have any questions about any aspect of this privacy policy and, in particular if you would like to object to any processing of your personal information that we carry out for our legitimate organisational interests.