1. About this Policy
1.1 We appreciate your interest in our products and services and your visit to this website. Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
1.2 This policy sets out how Vivacity handles your personal information, including when and why it is collected, used and disclosed and how it is kept secure.
1.3 You will find our contact details at the end of this policy which you can use if you have any questions, including how to update or access your personal information or to make a complaint.
1.4 This policy may change, so please check from time to time to ensure that you're happy with any changes. Please see further changes to this policy in Section 9.
1.5 This policy was last updated in May 2018.
2. Who we are
2.1 When you deal with Vivacity Culture and Leisure, we will be the 'controller' of your personal information. A 'controller' is a company that decides why and how your personal information is processed.
2.2 Where this policy refers to "we", "our", "us" or “Vivacity” below, unless it mentions otherwise, it's referring to Vivacity Culture and Leisure.
3. How and what personal information we collect
3.1 We may collect and process personal information about you. This may be collected in a number of different ways including:
Personal information you give to us:
- Information you give to us online for example via our websites/apps or our social media pages
- You may give your personal information by email, telephone or directly to one of our staff or volunteers at our venues, either verbally or by completing a form.
- You may also give us information about you when you submit reviews, profiles, images, videos, instructions, comments, feedback, ideas, suggestions or other information or materials via our venues or social media, whether relating to Vivacity venues, promotions or other matters upon which you wish to comment.
- You may be operating a small business and be a supplier or customer of Vivacity operating from a home address or personal bank account.
- You may be a customer, volunteer, trustee or employee, either current, prospective or historical
- This is not an exhaustive list and you may have a relationship with Vivacity not specifically mentioned where Vivacity processes your personal data
You may wish to access these links:
Privacy Policy Job Applicants
Privacy Notice for Current and Former Employees
Privacy Policy Volunteering Applicants
Link to Volunteers and Former Volunteers Privacy notice
You must ensure in all instances that the information you provide is personal to you and no one else (for example you must only provide an email address that only accessible by you). You must also ensure that the information you provide is accurate and up to date. By providing information about you to us you warrant that the information you provide is personal to you and is accurate and up to date, and that you will keep us informed of any changes. The same applies if you are a parent or guardian, and are providing Vivacity with any information about a child in your care.
3.2 Personal information we collect about you:
We may automatically collect the following personal information:
Our web servers store as standard details of your browser and operating system, the website from which you visit our website, the pages that you visit on our website, the date of your visit, and, for security reasons, e.g. to identify attacks on our website, the Internet protocol (IP) address assigned to you by your internet service. We collect some of this information using cookies - please see Cookies in Section 9.2 for further information. We may also collect any personal information which you allow to be shared that is part of your public profile on a third party social network.
We also collect data about you at various times for example:
- When you register with us for a Vivacity card (libraries or sports)
- When you register to have a Key theatre account
- When you sign up to our newsletters
- Other occasions when signing up to use Vivacity services
- When you visit a Vivacity venue
We use this data to track your customer journey and history with Vivacity
3.3 Personal information we may receive from other sources:
We may obtain certain personal information about you from third party sources outside our business which may include GPs. In these circumstances, the third party is responsible for ensuring you have been informed and given consent to have your details passed onto us via these methods.
As part of our security and safeguarding operation, we will also be collecting personal images relating to visitors and customers to our facilities from CCTV systems. The information recorded through these technologies is held on our CCTV systems and storage will vary by site. The CCTV footage may be stored longer for accident and incident reporting, this data may be shared with third parties such as insurance providers and legal advisors, government organisations who we are required to report on incidents by law or the police to investigate a crime. This information is also collected to ensure that we comply with our legal responsibilities in relation to Health and Safety investigation and reporting, to prevent and detect crime, or to protect vital interests of individuals.
3.4 Please see further how we use your personal information in Section 4 for details of the purposes for which we use the personal information we obtain from these sources and the legal basis on which we rely to process that information. The remaining provisions of this policy also apply to any personal information we obtain from these sources.
4. How we use your personal information
4.1 Where you have provided CONSENT
We may use and process your personal information for marketing purposes where you have consented for us to do so for the following purposes:
- To receive news, offers, and information about Vivacity services.
- To enter you into a prize draw, competition or other promotion (where requested). This may require disclosure to third parties for example card processing agencies, banks, shipping providers and carriers, fraud protection agencies and suppliers of gifts and prizes for our competitions, prize draws and other promotions.
4.2 Where required to perform a CONTRACT with you
Whenever you use or pay for a service, you are entering into a contract with Vivacity whilst you are using this service. Vivacity may need personal information about you in order to provide you with the service you have requested.
For example, if you buy a theatre ticket and ask us to post your ticket we will need your address in order to do so. We will also need your payment details.
The data we require will vary by service.
If you have made an enquiry about one of our services, but have not yet bought anything, we may also require personal information in order to process your enquiry.
4.3 Where it is in your VITAL INTEREST
We may use your personal information to contact you if there are any urgent safety issues to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way. This may include your health data to access some of our services.
4.4 Where it is a PUBLIC TASK
Some of the services Vivacity provides to the City of Peterborough are specific tasks in the public interest which are laid down by law. For example, some of our archives service
4.5 Where required to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations including: (i) to assist HMRC, the Police or any other public authority or criminal investigation body; (ii) to identify you when you contact us; and (iii) to verify the accuracy of data that we hold about you.
4.6 Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
- For analysis and profiling to inform our marketing strategy, and to enhance and personalise your customer or visitor experience;
- For market research in order to continually improve the products and services that we and our authorised partners deliver to you;
- To administer our websites and for internal operations, including troubleshooting, testing, statistical purposes;
- For marketing activities (other than where we rely on your consent). Vivacity may send you information regarding services similar to those you have previously accessed. In these circumstances you will always be offered an opportunity to opt out of receiving this information in the future.
- To correspond and communicate with you;
- To comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- To enforce or protect our contractual or other legal rights or to bring or defend legal proceedings; and
- For general administration including managing your queries, complaints, or claims, and to send service messages to you.
5. Others who may receive or have access to your personal information
5.1 Our suppliers and service providers
We may disclose your information to our third-party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud service providers (such as hosting and email management) or advertising agencies, administrative services or other third parties who provide services to us.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service. We have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
5.2 Third parties who provide products and services
We work closely with various third parties to bring you a range of products and services which are complementary to ours.
When you enquire about or purchase one or more of these products or services through us (e.g. via our websites) you will be made aware that this product is not a Vivacity service but that it’s provided by a third party, the relevant third party may use your details to provide you with information and carry out their obligations arising from any contracts you have entered into with them.
Third-party product providers may share your information with us which we will use in accordance with this policy. In some cases, they will be acting as a controller of your information and therefore we advise you to read their privacy policy.
5.3 Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. However, we will always take steps with the aim of ensuring that your privacy rights continue to be protected.
6. How long we keep your personal information for
6.1 If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information (the legal basis described in section 4) and our obligations under other laws.
6.2 We do not retain personal information in an identifiable format for longer than is necessary.
6.3 We may need your personal information to establish, bring or defend legal claims, in which case we will retain your personal information for 7 years after the last occasion on which we have used your personal information in one of the ways specified in Section 4.
6.4 The only exceptions to this are where:
- The law requires us to hold your personal information for a longer period, or delete it sooner;
- You exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted in this section 6, or because we are required under the law (see further erasing your personal information or restricting its processing in Section 7);
- In limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
7. Your rights
7.1 Your ‘Data subject’ rights:
You have the right to ask for a copy of the information that we hold about you. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7.2 Accessing your personal information
You have the right to ask for a copy of the information that we hold about you. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
7.3 Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
In the meantime, if you change your name or address/email address, or you discover that any of the other information we hold is inaccurate or out of date, please let us know
7.4 Withdrawing your consent
Where you receive marketing information from Vivacity, either because you have consented, or because of a legitimate interest, (see legal basis in section 4), we will always provide a way for you to opt out of receiving this information in the future. If you withdraw your consent, our use of your personal information before you withdrew is still lawful.
7.5 Objecting to our use of your personal information
Where you have not consented, you can object to Vivacity storing and processing your personal data. You may ask for your personal information to be removed from our systems and unless there is a reason that the law allows us to use your personal information for longer, we will make reasonable efforts to comply with your request.
Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection laws, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
7.6 Restricting processing
You may also ask us to restrict processing your personal information in the following situations:
- where you believe it is unlawful for us to do so,
- you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings.
In these situations, we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company, or in connection with legal proceedings
7.7 How to access your rights:
- If you receive our newsletters or other information by email and wish to change what sort of information you receive or opt out of receiving further emails, the easiest way to do this is to click on ‘unsubscribe’ or ‘update my preferences’ at the bottom of the email. This will be processed within 72 hours.
- If you do not have an email from us, or to access other rights, the next easiest method is to fill out our online-form, which will ensure you give us all the information you need to carry out your request within 30 days. Please click here.
- You can speak to our staff at any Vivacity venue and they should be able to assist you
- Failing that, you can email us directly at data.protection@vivacity.org and we will respond within 30 days
- Or you can send a letter at the address at the end of this policy
8. Security/Website/Cookies/Links/Social plugins
8.1 Security measures we put in place to protect your personal information
When someone visits www.vivacity.org we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various venues. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
8.2 Website
When someone visits www.vivacity.org we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various venues. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.
8.3 Use of ‘Cookies’
'Cookies' are small pieces of information sent to your device and stored on its hard drive to allow our websites to recognise you when you visit. Further guidance on how to delete cookies can be found at www.aboutcookies.org.
8.4 Links to our website
It is important to note that the Vivacity website contains links to other websites of affiliated partners and that those sites may not follow the same privacy policies as Vivacity. These sites may send their own cookies to you, and may collect data and make use of it that Vivacity would not. The use of any information or materials that you may access at these external sites is purely voluntary.
9. Changes to this Policy
The internet and data privacy best practices are both developing. We therefore reserve the right to revise this Privacy Policy at any time. If this Privacy Policy changes in any way, we will place an updated version on this page. Regularly reviewing this page ensures you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
10. Linked Policies
In addition to this policy, Vivacity has further privacy policies which relate specifically to people potentially, currently or historically working for or volunteering for Vivacity.
Privacy Policy Job Applicants
Privacy Notice for Current and Former Employees
Privacy Policy Volunteering Applicants
Link to Volunteers and Former Volunteers Privacy notice
11. Contact us
Vivacity tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention in the first instance, if they think that our collection or use of information is unfair, misleading or inappropriate.
This privacy policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of Vivacity’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
If you have contacted us and are unhappy with our response, and want to make a complaint about the way we have processed your personal information, you can contact the Information Commissioner’s Office:
www.ico.org.uk/concerns.
If you require further information about your data, or wish to complain or comment please click here:
If you wish to update the information we hold about you please contact the venue you normally visit or click here:
Alternatively you can write to us:
Data Protection
Vivacity Culture & Leisure
Central Library
Broadway
Peterborough
PE1 1RX
Data.protection@vivacity.org
