We are committed to protecting your personal information and to being transparent about the information we hold about you. Using personal information allows us to develop a better understanding of our patrons, and in turn to provide you with relevant and timely information about the work that we do.
Personal information also helps us as a charity to engage with current and potential donors. The purpose of this policy is to give you a clear explanation about how we collect and process your personal information through your use of our website & elsewhere, including any data you may provide when you sign up to our newsletter(s), purchase a ticket or make a donation.
We will use the information that we collect about you in accordance with:
- The Data Protection Act 1998
- The Privacy and Electronic Communications (EC Directive) Regulations 2003
- The EU General Data Protection Regulation (Regulation EU 2016/679), (‘GDPR’) which becomes effective from 25 May 2018
This policy explains:
- Who we are
- Information we may collect about you
- How we collect your data
- How we may use your information
- Disclosure of your details to third parties
- Security of your personal information
- Data retention
- Your legal rights
- Contact details and further information
If you have any questions, please contact the Data Protection Officer at The Banbury Museum Trust using the contact details at the end of this policy.
1. Who We Are
Banbury Museum Trust is constituted as an educational charity, with a wholly owned subsidiary trading company, which gifts all its profits to the charity. Our charity is registered in England and Wales, number 1153109. Banbury Museum Trading Ltd is a company limited by guarantee registered in England and Wales, number 8900745.
We receive approximately two thirds of our income from statutory bodies, including Cherwell District Council. The rest of our income comes from ticket sales, trading activity in our shop, and from donations – from individuals, from trusts and foundations, and from corporates.
2. Information we may collect about you
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, i.e. anonymous data.
We may collect, use, store and transfer different kinds of personal information about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. This also includes us making a note of conversations we have had with you in person and/or communications you sent to Banbury Museum. This helps us to manage our relationship with you and ensures you only receive communications from us that are relevant and timely.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal information
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a ticket). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Users under 18
We understand that people aged under 18 may use our website. To request to see our safeguarding policy, please contact us using the contact details at the end of this policy.
3. How we collect your data
We collect different information about you in a number of ways:
Information you give us
When you create an account on our website, buy tickets, sign up to our newsletter, request marketing materials, give us feedback or make a donation, we will store the personal information you give to us such as your name, email address, postal address, telephone number and card details. We will also keep a record of your purchases and donations.
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
Information from third parties
We occasionally receive information about you from third parties as set out below:
- Analytics providers such as Google
- Advertising networks such as Facebook
- Search information providers such as Google AdWords
4. How we may use your information
We will only use your personal information when the law allows us to.
Most commonly, we will use your personal information in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where we have your explicit consent before using your personal information in that specific situation. However, generally we do not rely on consent as a legal basis for processing your personal information and you have the right to withdraw consent to marketing at any time by contacting us. You will find the relevant contact details at the end of this policy.
Purposes for which we will use your personal information
We have set out below, in a table format, a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Please note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us 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.
||Type of data
||Lawful basis for processing including basis of legitimate interest
|To register you as a new customer
|Performance of a contract with you
|To process and deliver your ticket purchase including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw or complete a survey
(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 administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|(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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
|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 and communications with you, customer relationships and experiences
|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
|Necessary for our legitimate interests (to develop our products/services and grow our business)
We aim to communicate with you about the work that we do in ways that you find relevant, timely, respectful, and never excessive. To do this, we use data that we have stored about you, such as which events you have booked for in the past, as well as any contact preferences you may have told us about.
We use our legitimate organisational interest as the legal basis for communications by post and email. In the case of postal mailings, you may opt out of receiving these at any time using the contact details at the end of this policy.
In the case of email, we will provide you with an option to unsubscribe in every email that we send you.
As part of our service to you, we may contact you by email or telephone to provide essential information related to your purchase and visit.
Banbury Museum Trust is a registered charity. Under our legitimate organisational interest, we may contact you by post or occasionally by telephone, to seek your support for our philanthropic priorities. This contact will not be more frequent than once per month and you are able to opt out at any time by using the contact details at the end of this policy.
Additionally, and only if you have given your consent, we may contact you by email to seek your financial support. Click here to read our Promise to Supporters which outlines how we communicate with and respect our donors.
Other processing activities
We may use profiling techniques or third-party wealth screening and insight companies such as Prospecting for Gold 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 about potential philanthropic support. Such information is compiled using publicly available data about you.
You have the right to object to any of this processing at any time. If you wish to do this, please use the contact details at the end of this policy.
5. Disclosure of your details to third parties
There are certain circumstances under which we may disclose your personal information to third parties. These are as follows:
- To our service providers who process data on our behalf and on our instructions (for example our ticketing system software provider). We require all third parties to respect the privacy of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
- 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).
- To specific, named visiting companies whose work you have attended / participated in. In these cases, we will always ask for your explicit consent before disclosing your personal information.
We may share anonymised personal information with other organisations, particularly Cherwell District Council, Arts Council England and the Museums Association, who use this to analyse our audience development programmes, ticket sales and self-generated funding to understand the impact of the public investment made in Banbury Museum.
We do not sell personal details to third parties for any purpose.
6. Security of your personal information
Your 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). You can find more information about this standard (https://www.pcisecuritystandards.org/pci_security/). We may give the option for you to store your card details safely for use in future transactions. This is carried out in compliance with PCI-DSS and in a way where none of our staff members can see your full card number. We never store your 3 or 4-digit security code.
Security of your personal information
We have put in place 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 and that they will only process your personal information on our instructions. The third parties will also be subject to a duty of confidentiality.
We will not transfer, process or store your data anywhere that is outside of the European Economic Area, unless we have a contractual agreement in place that is of an equivalent standard to GDPR.
7. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for 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.
8. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal information, as follows:-
- a) Request access to your personal information
You have a right to request a copy of the personal information that we hold about you. Please use the contact details at the end of this policy if you would like to exercise this right, or any of the rights listed below. If you are a European citizen and consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, i.e. the Information Commissioner’s Office.
- b) Request correction of your personal information
You have the right to request that we correct the personal information we hold about you, although we may need to verify the accuracy of the new information you provide to us.
- c) Request erasure of your personal information
You have the right to request that we delete or remove personal information where there is no good reason for us continuing to process it. Please note that we may not always be able to comply with your request for erasure if there are specific legal reasons- which will be notified to you at the time of your request.
- d) Object to processing of your personal information
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- e) Request restriction of processing your personal information
You have the right to request that we suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- f) Request transfer of your personal information
You have the right to request that the personal information we hold about you is transferred to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- g) Right to withdraw consent
In circumstances where we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Please also note the following:-
No fee usually required
You will not have to pay a fee to access your personal information (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
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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 three days. Occasionally it may take us longer 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.
10. Contact details and further information
Please also contact us if you have any questions about the information we hold about you, or to change your contact preferences with us:
Email us: email@example.com
Call us: 01295 236165
Write to us:
Spiceball Park Road