This privacy notice is provided in a layered format so you can click through to the specific areas set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE
The Data Controller – Who we are
Under the General Data Protection Regulations (“GDPR”) a “Data Controller” is a natural or legal person, which alone or jointly with others, determines the purposes and means of personal data processing. A “Data Processor” is a natural or legal person which processes personal data, whether or not they are a third party.
The Company has subsidiaries in Germany, Paris and the United States and may operate other subsidiaries or branch offices from time to time, including subsidiaries outside of the E.U. (together with the Company, the “Group”), which may act as a Data Controller or Data Processer from time to time. Wildkat is the controller and responsible for all websites in the Group.
We may also act as Data Processor on behalf of our clients where our role is to carry out or to administer campaigns and collect or process data on behalf of our clients (for example, surveys, marketing sign ups and competitions).
Our contact details
Wildkat Group Limited,
26 Bloomsbury Street,
Your details and any changes
We need to ensure that the data that we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
Third Party Links
We sometimes provide you with links to other websites or mobile applications, but these websites and mobile applications are not under our control. We are only responsible for the privacy practices and security of our Services. We are not responsible for the privacy policies, content or security of any linked websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit.
Third Party Campaigns – Data Processing
From time to time we may carry out marketing campaigns, promotions, surveys, competitions and data collection initiatives (collectively “Campaigns”) on behalf of our clients. In some of these instances, we act only as the Data Processor on the predefined instructions of our client, the Data Controller. Where we act as Data Processor we shall abide by the contractual terms that Data Processors and Data Controllers are required to include in their contracts under the GDPR and with other requirements of the GDPR which relate to Data Processors, including, without limitation:-
2. WHAT DATA DO WE COLLECT ABOUT 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 as follows:-
From time to time we may also collect and use 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 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 Aggregate 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.
The only Special Category of Personal Data we collect about you is information you provide to us about your health (for example when you are buying tickets for wheelchair accessible spaces at one of our events or as part of the recruitment process to enable us to make reasonable adjustments). We do not collect details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic or biometric data. Nor do we collect any information about criminal convictions and offences, other than those offences committed or allegedly committed at one of our events where it is in our legitimate interests to do so and is in order prevent or detect an unlawful act, where it is necessary in connection with any legal proceedings or prospective legal proceedings, to obtain legal advice, or is otherwise necessary for the purposes of establishing, exercising or defending legal rights.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
Sources of personal data
We use different methods to collect data from and about you including through:
We may also receive personal data about you from third parties and public sources as set out below.
We may combine any personal data about you that we receive from you and from third parties.
4. HOW DO WE USE YOUR PERSONAL DATA?
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you vial email or text message or taking a photograph of you at one of our events. You have the right to withdraw consent at any time by contacting email@example.com.
With your explicit consent we process personal data about your health to provide you with tailored services such as wheelchair accessible space.
Purposes for which we will use your data
We have set out below, in a table format, a description of the ways we, or our third party processers acting on our behalf, plan to process your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To send you information which you have requested (e.g. e-shots, corporate brochure) and respond to your enquiries||Identity Contact||Necessary for our legitimate interests (for the effective operation of our business and to provide you with the best service)|
|To provide you with any of the Services||Identity Contact Transaction||Performance of a contract with you Necessary for our legitimate interests (for the effective operation of our business and to provide you with the best service)|
|To manage our relationship with suppliers, enable us to pay suppliers and charge, invoice or refund customers (where applicable)||(a) Identity (b) Contact (c) Financial (d) Transaction||(a) Performance of a contract with you (b) Necessary for our legitimate interests (keeping financial records for good business governance)|
|To investigate incidents which take place at our events and complaints||Identity Contact Miscellaneous||Necessary to comply with a legal obligation Necessary for our legitimate interests (to investigate illegal, health and safety and other incidents which have happened at our events, to provide evidence in the event of legal proceedings)|
|Photographs of attendees at our events||Identity||Necessary for our legitimate interests (to capture footage of events for clients)|
|To verify your online identity for security purposes||Identity Contact Profile||Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to prevent fraud)|
|To enable you to partake in a prize draw, competition or complete a survey or review||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business, to confirm delivery of a prize, to improve our services)|
|To notify you of employment opportunities and process recruitment applications||(a) Identity (b) Contact (c) Profile (d) Marketing and Communications||Necessary for our legitimate interests (to recruit employees)|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity (b) Contact (c) Technical||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation|
|To deliver relevant marketing communications to you in order to market our Services including, where applicable, processing your registration, creating custom marketing audiences on third party websites such as Facebook and profiling||(a) Identity (b) Contact (c) Technical (d) Financial (e) Profile||Necessary for our legitimate interests (in order to effectively market our Services and ensure they operate in a commercially suitable way which is tailored to your use and interests)|
|To deliver relevant website content to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical (b) Usage||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile||Necessary for our legitimate interests (to develop our products/services and grow our business)|
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.
You may receive marketing communications from us if you requested information from us or purchased goods or services from us.
Third party marketing
We will get your express opt-in consent before we share your personal data with any company outside of the Group for marketing purposes.
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 email@example.com.
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.
5. HOW DO WE SHARE YOUR PERSONAL DATA?
We may share your personal data with other companies in the Group.
We will share your personal data with the data processors that help us to provide the Services. These include the following companies and any service provider which replaces them from time to time:-
We will also disclose your personal data to third parties in the following circumstances:
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.
Save as expressly detailed above in this section, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent.
6. WHERE DO WE TRANSFER YOUR DATA?
Your personal data may be transferred to, and processed in a location outside of the European Economic Area (EEA).
Our subsidiary and many of our external third party processers are based outside of the EEA so their processing of your personal data will involve a transfer outside the EEA.
7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including 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.
We shall retain the following data for the following periods:-
We will retain your personal data for longer if we believe we may need them in order to respond to any claims, to protect our rights or the rights of a third party, and we will retain your personal data for longer if we are required to retain them in order to comply with applicable laws.
We will always retain your personal data in accordance with data protection law and never retain your personal data for longer than is necessary. If you have any questions about our retention policy contact firstname.lastname@example.org.
8. HOW DO WE PROTECT YOUR PERSONAL DATA?
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.
We cannot guarantee the security of your personal data when you transmit it to us. For example, if you email us your personal data, you should be aware that email is not a secure transmission method. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to us and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
9. WHAT ARE YOUR LEGAL RIGHTS?
You may contact our Data Protection Manager by email at email@example.com at any time, to:
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.
What we may need from you
Your request must include your name, email address and postal address and we may request proof of your identity. Please allow at least seven working days for us to process your request.
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.
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.
Objection to legitimate interest processing
Where you object to processing personal data based on legitimate interests we can continue to process such data if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or where the processing is taking place for the establishment, exercise or defence of legal claims.
Withdrawing your consent
Where we are processing your personal data based on your consent, you may change your mind and withdraw your consent at any time.
You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email.
You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us at firstname.lastname@example.org.
The consequence of you withdrawing consent might be that we cannot do certain things for you.
Right to lodge a complaint with a supervisory authority
You may also make a complaint to a supervisory authority for data protection matters. In the UK, this would be the UK Information Commissioner’s Office (https://ico.org.uk/). If you live in another EEA country, you may complain to the supervisory authority in your country. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.