- Purpose of policy
At Classical Opera we are committed to protecting your personal information and being transparent about what information we hold about you. Using personal information allows us to fulfil our obligations to you (for example, when you purchase a ticket or product from us), and to provide you with relevant and timely information about the work that we do. As a charity, it also helps us to engage with existing and potential donors and supporters.
Your support is vitally important in helping us to deliver our work, and we want to maintain the trust and confidence of each and every one of our audience members and donors, as well as everyone who visits our website. The purpose of this policy is to give you a clear explanation about how we collect and use the personal information we collect from you directly and from third parties.
We use your information in accordance with all applicable laws concerning the protection of personal information. This policy explains:
- What information we may collect about you;
- How we may use that information;
- In what situations we may disclose your details to third parties;
- Information about how we keep your personal information secure, how we maintain it and your rights to be able to access it.
- Who we are
Classical Opera (including its brand The Mozartists) is a registered charity, and is funded by various trusts, foundations, companies and grant-giving bodies, and by individual donors and supporters. Our registered charity number in England and Wales is 1063387 and we are also registered as a company limited by guarantee in England and Wales under registration number 3361716.
You can find out more about our work and how we are governed here.
- Information collection
Generally, we collect your information when you decide to interact with us. We collect various types of information in a number of ways:
Information you give us
For example, when you sign up to our mailing list, we will collect and store your name and email address and, where applicable, your postal address. When you buy tickets or a CD, become a member, or make a donation, we’ll store personal information that you give us such as your name, email address, postal address, telephone number, company (if provided) and any other relevant details that you choose to share with us (for example, any relevant access requirements or preferred seating at a particular venue). We will also store a record of your purchases and donations. If you use social media or messaging services, then depending on your settings or the privacy policies of the independent organisations in question, you might also have granted us permission to access your information from those accounts or services. If you sign up to receive offers for those aged 36 and under (our ‘Age of Mozart’ scheme) we may store your date of birth.
Information about your interactions with us
For example, when you visit our website, we may collect your public IP address as well as information about how you interact with our content and advertisements. A public IP address is a unique number which allows a computer, group of computers or other internet-connected device to browse the internet. The log file records the time and date of your visit to a particular site, the pages that were requested, the referring website (if provided) and your internet browser version. We collect this information in order to help us diagnose and manage our website, to audit the geographical make-up of our users, and to establish how they have arrived at our website. We may also store a record of any communications that we send to you, and in the case of emails we keep a record of which ones you have opened and which links you have clicked on. These activities help us to ensure that our website and mailings remain relevant and effective. For more information on this type of data collection, please see our section on Cookies, which can be found below.
Information from third parties
We sometimes receive information about you from third parties with whom we have worked (for example, venues or festivals). These independent organisations will only share your information with us when:
- You have given your consent for them to do so in order that we may keep you informed about our work. You can opt out of receiving our communications at any time by contacting us or by following the instructions at the bottom of our circular email communications; and / or
- It is necessary in order for us or the independent organisation to fulfil a contract with you.
From time to time we may also receive information from individuals – for example, an existing supporter might recommend that we contact a friend of theirs who they feel would be interested in our work.
On occasion we may also make use of third party research companies to provide general information about you, compiled using publicly available data. We will only collect and process such information where we have a legitimate business interest in doing so, and only then when our interests do not outweigh your own.
Sensitive personal data
Data Protection law recognises that certain categories of personal information, such as health information, race, religious beliefs and political opinions, are more sensitive than others. We do not usually collect this type of information about our audiences, customers, donors or supporters unless there is a clear reason for doing so. As an example, we might keep a record of relevant information about an individual who has specific access requirements in order that we can provide an efficient and enjoyable service at our performances and events.
- Legal basis
There are three bases under which we may process your data:
When you make a purchase from us, you are entering into a contract with us. In order to perform this contract we need to process and store your data. For example, we may need to contact you by email or telephone in the case of cancellation of a show, or in the case of problems with your payment.
Legitimate business interests
In certain situations we collect and process your personal information for purposes that are in our legitimate organisational interests. However, we only do this if there is no overriding prejudice to you by using your personal information in this way. We describe below all situations where we may use this basis for processing.
With your explicit consent
For any situations where neither of the two bases above are appropriate, we will instead ask for your explicit consent before using your personal information in that specific situation.
- Marketing communications
We aim to communicate with you about the work that we do in ways that you find relevant, timely, useful and respectful. To do this we use data that we have stored about you, such as your name, postal address, email address or phone number as well as any preferences you may have told us about (for example, if you would like to know about our ‘Age of Mozart’ ticket offers for people aged 36 or under).
When we have reason to believe that you are interested in hearing about our work (for instance, when you purchase a ticket or CD from us), we use our legitimate organisational interest as the legal basis for communications by email. We will give you an opportunity to opt out of receiving circular emails the first time you purchase a product from us, make a donation or sign up to our emailing list. If you do not opt out at this stage, we will provide you with links to unsubscribe or update your preferences in every circular email that we subsequently send you (please note that personalised communications sent to you directly by a named member of our staff will not include such links, but you may still contact us to let us know your preferences). Alternatively, you can opt out or update your preferences by contacting us using the details given at the end of this policy. Please note that in our circular email communications we sometimes share news and updates from other like-minded organisations which we think you might like to hear about. Under no circumstances will we share your data with these third parties unless you have given us your explicit consent for doing so.
We may also use our legitimate organisational interest as the legal basis for contacting you about our work by post or telephone. In the case of postal mailings, you may object to receiving these at any time by contacting us using the contact details given at the end of this policy. If you would prefer not to be contacted by telephone, you can register with the Telephone Preference Service, or contact us using the details given at the end of this policy. Please bear in mind that this does not apply to telephone calls that we may need to make to you related to your purchases, donations or ticket bookings (as above).
- Other processing activities
In addition to marketing communications, we also process personal information in the following ways that are within our legitimate organisational interests:
- We may analyse data we hold about you and your interactions with us to ensure that the content and timing of communications that we send you are as relevant as possible;
- We may use your data to show you advertisements or informative content on social media platforms and other third party websites that you may use (for example, Google). The information shared with these platforms is pseudonymised to protect your personal data;
- In order to improve our website, we may analyse information about how you use it and the content and ads that you interact with;
- We may use booking data and publicly available information to group and segment data, helping us to better understand the demographics of our audiences, customers, donors or supporters;
- We may analyse data we hold about you in order to detect and reduce fraud and credit risk;
- In a small number of cases, we may use profiling or wealth screening techniques to provide us with information about you that will help us to communicate in a relevant way with you, in particular when we are approaching you or your organisation about potential philanthropic support. Such information is compiled using publicly available data about you, and might include: residential location, wealth and assets, family, career, donations to other organisations (including political parties where they are made public by the individual) and hobbies and interests. This helps us understand the background of the people who may choose to support us and helps us to make requests for gifts to those who may be able and willing to give. We may also use publicly sourced images to help identify individuals who attend our events. Please note we do not collect data about children, except where this information is given personally by a parent or legal guardian, or where it is made public by the same;
- From time to time we may cross-check your data against recognised data hygiene files (such as the National Change of Address file) or publicly available information, and cleanse or update your data to ensure that it remains accurate;
- From time to time we may also add to your record using publicly available information found in places such as Companies House, articles and newspapers.
In all of the above cases we will always keep your interests at the forefront to ensure that your fundamental rights and freedoms are not overridden by our own interests. You have the right to object to any of this processing at any time. If you wish to do this, please contact us using the contact details at the end of this policy. Please bear in mind that if you object this may affect our ability to carry out tasks above that are for your benefit.
- Fundraising communications
We will only send you email communications soliciting your support when we have your consent to do so, although if we have a legitimate business interest in doing so we may still contact you by phone or post to inform you of opportunities to support our work. If you would prefer us not to contact you about fundraising, you can amend your preferences by contacting us using the details given at the end of this policy.
- Sharing your data with third parties
We do not share, sell, rent or trade your data to third parties without your prior consent, except in circumstances when it is necessary for us to do so in order to provide a service that you have requested or to comply with the law. These are as follows:
- Where we need to share your information with service providers who process data on our behalf and on our instructions. Examples of such service providers may include (but are not limited to):
- Mailing houses who deliver our postal mailings;
- Database services which we use in our day-to-day administration;
- Organisations that organise or administer any competitions that you enter;
- Data services who help us to segment and understand our audience by providing additional information so that we can ensure our communications to you are relevant and useful.
In these cases we require that these third parties comply strictly with our instructions and with data protection laws, and that they do not process your data for anything other than the purpose of providing the agreed service;
- 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);
- In the event that Classical Opera is sold or integrated with another business your details may be disclosed to our advisers, any prospective purchasers and their advisers, and the new owners of the business. In this event, all recipient organisations will be subject to privacy practices no less onerous than set out in this policy.
- Your debit and credit card information
We accept debit and credit card payments through our website and over the phone using the third party payment provider Braintree Payments (a division of PayPal). Payments made through our website are submitted directly to Braintree Payments in such a way that none of our staff members are able to see your full card number. We never store your 3- or 4-digit security code.
When you make a payment over the phone, you will need to provide your card details to the member of our staff who processes your payment. They will enter your card details into the Braintree Payments portal and submit the transaction for processing, after which time your card details will only be available to us in encrypted form.
We will not record your unencrypted card details in any way, and neither do we store your card details on our own servers.
We strongly discourage you from sharing your credit or debit card details in any written form, including by e-mail. Please note that should you choose to share your card details with us in this way, we cannot accept liability for its interception and misuse (whether fraudulent or otherwise) by third parties.
To find out more about cookies and how to control them, visit www.allaboutcookies.org
- Maintaining your personal information
We will store your personal information for as long as is reasonably necessary for the purposes set out in this policy and to comply with legal obligations. In line with our legitimate business interests, if you purchase a ticket or other product from us we will typically keep your data for up to ten years unless you request us not to do so. If you have made a philanthropic financial transaction (i.e. when you purchase a membership or make a donation), we may keep a record of your name and donation(s) indefinitely, as it is important to be able to verify where our voluntary income has come from. We also feel that it is important to be able to acknowledge your prior support should you choose to come back to us in the future. We will only process your data when we feel our interests do not outweigh your own. If you would like to object to our storing and processing your data, you can do so at any point by contacting us using the details given at the end of this policy. Please be aware, though, that we are legally obliged to keep a record of any financial transactions for six years from the end of the financial year in which the transaction was made.
Any objections 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. For example, if you ask that we stop sending you direct marketing communications, we will need to keep a record of your postal or email address to ensure that we do not contact the same address in the future.
We aim to keep your personal information up-to-date and correct. If any of your details change, please notify us by contacting us using the details included at the end of this policy. On occasion we may also update the information we hold about you using publicly available data.
- Security of your personal information
We maintain appropriate safeguards (both in terms of our procedures and the technology 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.
In order to carry out our standard business practices, we sometimes need to transfer your personal information to countries outside of the European Economic Area (EEA). For example, our primary email marketing service (MailChimp) is based in the USA. In such instances we will always ensure that the recipient organisation has sound data practices before we transfer your data.
- 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 at the end of this policy if you would like to exercise this right. Please note it can take up to 28 days for us to comply with a data access request.
If you would like to make a complaint to the relevant supervisory authority, you can do so by contacting The Information Commissioner’s Office: www.ico.org.uk
Although we follow strict procedures to limit risk to your personal information, we would like to remind you that no data transmission via the internet, phone or postal service is entirely secure. We cannot guarantee the security of any information which you disclose to us, which you do so at your own risk. Furthermore, we accept no liability for damages brought against you if you share another individual’s personal information without that individual’s prior consent.
- Updates or changes to this policy
- Helpful documents
For more information about cookies: www.allaboutcookies.org
Telephone Preference Service: http://www.tpsonline.org.uk/tps/index.html
- Contact details
Tel: 020 8846 9744
Post: Classical Opera
11 Glenthorne Road
London W6 0LH