Updated July 2018
- By submitting your personal information you consent to the use of that information as set out in this policy.
1.1 The International Pole Convention (“we”, “us” or “PoleCon”) takes the privacy of your information very seriously. Our Privacy Notice is designed to tell you, the user of our services, about our practices regarding the collection, use, and disclosure of personal and other information about you, your enterprise or your organization that may be provided via our website (the “Site”) and any other digital or other product we provide, or collected through other means such as an online form, email, or telephone communication.
1.2 We collect personal data from people based in EU member states and so this policy applies to them in its entirety. We also collect personal data from people outside of EU member states. We adopt the same organizational approach in regard to all personal data we collect (e.g. its security and retention) but for personal data that is collected from people outside of EU member states this policy acts as guide only and does not confer legal rights to such people, in particular sections 8, 10, and 11.2.
- Basis on which we use personal information
2.1 Personal information we hold about you will be collected/used either because:
2.1.1 you have consented or explicitly consented to the use for the specific purposes described in this notice;
2.1.2 the use is necessary in order for us to comply with our obligations under a contract between you and us; or
2.1.3 compliance with a legal obligation;
2.1.4 the use is necessary in pursuit of a “legitimate interest”, a legitimate interest in this context means a valid interest we have or a third party has in use your personal information which is not overridden by your interests in privacy and security.
- Ways that we may collect your personal information
3.1 We may collect and process the following personal information (information that can be uniquely identified with you) about you:
3.1.1 information provided to sign up to our services;
3.1.2 your name, residential address, contact address and numbers, email address, photos and content you may have created or provided through your use of our services;
3.1.3 payment information we may use to collect payment (if applicable);
3.1.4 log-in details and information you provide when setting up a profile on the Site (if any);
3.1.5 a record of any correspondence between you and us;
3.1.6 replies to any surveys or questionnaires that we may use for research purposes;
3.1.7 details of your visits to the Site, the resources and pages that you access and any searches you make;
3.1.8 any information we may require from you when you report a problem or complaint;
3.1.9 the number of communications you make with us;
3.1.10 by taking photos at events.
3.2 If we do obtain your personal information from a third party your privacy rights under this notice are not affected and you are still able to exercise the rights contained within this notice.
3.3 You do not have to supply any personal information to us but our services may not be operable in practice without providing personal information to us. You may withdraw our authority to process your personal information (or request that we restrict our use – see section 9 – at any time (but our services may not be fully operable should you do so).
- Reasons why we process your personal information
4.1 We will use your information to:
4.1.1 ensure that the content of the Site is presented in the most effective manner for you and for your device;
4.1.2 customize the service to your preferences;
4.1.3 provide information, products and services to you;
4.1.4 assist in the administration of your service (if any);
4.1.5 assist in making general improvements to our services;
4.1.6 carry out and administer any obligations arising from any agreements entered into between you and us;
4.1.7 if you have signed up for an event with us we will be contacting you with information on that event;
4.1.8 manage your marketing preferences;
4.1.9 review your application to become a volunteer or for a job role;
4.1.10 to assist you with being a volunteer for us;
4.1.11 contact you and notify you about changes to our services or the services we offer, subject to the Privacy and Electronic Communications Regulations (except where you have asked us not to do this);
4.1.12 manage your registration with us (if any) and provide you with customer support;
4.1.13 analyze how our services are used and to identify trends;
4.1.14 administer our service and for internal operations, including troubleshooting, information analysis, testing, research, statistical and survey purposes.
4.2 We may also use aggregated, anonymized information which includes personal information you have supplied to sell advertising space on the Site or market services to other users.
- Information Retention
5.1 Our current information retention policy is to delete or destroy (to the extent we are able to) the personal information we hold about you in accordance with the following:
Health and safety records (e.g. an accident book) being held at physical premises At least 10 years
Records relevant for tax purposes 8 years from the end of the tax year to which the records relate
Personal information processed in relation to a contract between you and us 7 years from either the end of the contract or the date you last used our service, being the length of time following a breach of contract in which you are entitled to make a legal claim
Personal information held on marketing or business development records 2 years from the last date on which a information subject has interacted with us
5.2 For any category of personal information not specifically defined in this Notice, and unless otherwise specified by applicable law, the required retention period for any personal information will be deemed to be 7 years from the date of receipt by us of that information.
5.3 The retention periods stated in this Notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the information or if there is an on-going investigation into the information).
5.4 We review the personal information (and the categories of personal information) we are holding on a regular basis to ensure the information we are holding is still relevant to our business and is accurate. If we discover that certain information we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this information as may be required.
5.5 If you wish to request that information we hold about you is amended or deleted, please refer to clause 8 below, which explains your privacy rights.
- Sharing your information
6.1 We do not disclose any information you provide to any third parties other than as follows:
6.1.1 where you have chosen an authorized person such as a talent manager for us to share your information with;
6.1.2 where you have opted to share any of your content with any other user of the service or third party, you authorize us to deliver that content via email, SMS or other electronic messaging or communication system;
6.1.3 where information such as email addresses is passed to our IT Team who provide technical support or other services in the provision of our service;
6.1.4 where we carry out research to gain an insight into the use of our services, the results of this research (but not your personal information itself) may be transferred to interested third parties;
6.1.5 if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
6.1.6 in order to enforce any terms and conditions or agreements for our services that may apply;
6.1.7 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 reorganization, but we will take steps with the aim of ensuring that your privacy rights continue to be protected;
6.1.8 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6.2 Other than as set out above, we shall not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
7.1 We will take all reasonable steps to ensure that appropriate technical and organizational measures are carried out to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage. These measures may include (as necessary):
7.1.1 protecting our servers by both hardware and software firewalls;
7.1.2 locating our information use storage facilities in secure locations;
7.1.3 encrypting all information stored on our server with an industry standard encryption method that encrypts the information between your computer and our server so that in the event of your network being insecure no information is passed in a format that could easily be deciphered;
7.1.4 when necessary, disposing of or deleting your information so it is done so securely;
7.1.5 regularly backing up and encrypting all information we hold.
7.2 We will ensure that our employees are aware of their privacy and information security obligations. We will take reasonable steps to ensure that the employees of third parties working on our behalf are aware of their privacy and information security obligations.
7.3 This notice and our procedures for handling personal information will be reviewed annually.
7.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to the Site; any transmission is at your own risk. Once we have received your information, we will use the strict procedures and security features referred to in this clause to try to prevent unauthorized access.
- Your privacy rights
8.1 If you would like to update your personal information or let us know the personal information we hold is incorrect you may do so on our website here or by contacting us directly.
8.2 You have a right to know about how we protect your personal information, (as set out in this policy).
8.3 You always have the right to unsubscribe from our newsletter or any other services where we rely on your consent for holding your personal information. We will ensure you are unsubscribed as soon as possible but within 30 days.
8.4 You also have a right to restrict our use of your personal information and the right to object to your personal information being processed.
8.5 You have the right to ask us to stop using your personal information in certain ways (as set out in the policy).
8.6 You have the right to ask us to delete your personal information. Unless we have reasonable grounds to refuse to delete your personal information, we will securely delete the personal information in question within 30 days. The personal information may continue to exist in certain backup, but we will take all steps to ensure that it will not be accessible.
8.7 You have the right to request access to the personal information that we hold about you.
8.8 We will endeavor to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
8.9 If a breach is likely to result in a risk to your information rights and freedoms, we will notify you as soon as possible and we may also report it to the ICO.
- Other websites
9.1 Our Site may contain links and references to other websites. Please be aware that this notice does not apply to those websites.
9.2 We cannot be responsible for the privacy policies and practices of sites that are not operated by us, even if you access them via the Site and/or any other service that is operated by us. We recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
9.3 In addition, if you came to this service via a third party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
- Transferring your information outside Europe
10.1 As part of the services offered to you the information you provide to us is processed and stored at, countries or international organizations outside of the European Economic Area (EEA), specifically in the following ways:
- As part of a database of PoleCon customers
- As part of a payment processor
The information you provide may be transferred to countries outside the EEA that do not have similar protections in place regarding your data and restrictions on its use as set out in this policy. However, we will take steps to ensure adequate protections are in place to ensure the security of your information. The EEA comprises the EU member states plus Norway, Iceland and Liechtenstein. By submitting your information you consent to these transfers for the purposes specified above.
10.2 By submitting your personal information to us you agree to the transfer, storing or use of your information outside the EEA in the manner described above.
- Notification of changes to the contents of this notice
11.1 We will post details of any changes to our policy on the Site to help ensure you are always aware of the information we collect, how we use it, and in what circumstances, if any, we share it with other parties.
11.2 If we are unable to resolve any issues you may have or you would like to make a further complaint, you can contact the ICO by visiting http://www.ico.org.uk/ for further assistance.