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PRIVACY POLICY & COOKIES


INTRODUCTION

Welcome to The Really Useful Group Limited’s privacy notice.

The Really Useful Group Limited respects your privacy and is committed to
protecting your personal data. This privacy notice will inform you as to how we
look after your personal data when you visit our website (regardless of where
you visit it from) and tell you about your privacy rights and how the law
protects you.

Please also use the Glossary to understand the meaning of some of the terms used
in this privacy notice.

‍


1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how The Really Useful Group
Limited collects and processes your personal data through your use of this
website, including any data you may provide through this website when you sign
up to our mailing list(s) or take part in a competition or ticket lottery or
provide personal data as part of any audition process.

This website is not intended for children and we do not knowingly collect data
relating to children, save for where this data has been specifically provided as
part of an audition process and you have given your explicit consent to our
processing of this data.

It is important that you read this privacy notice together with any other
privacy notice or fair processing notice we may provide on specific occasions
when we are collecting or processing personal data about you so that you are
fully aware of how and why we are using your data. This privacy notice
supplements any other notices and is not intended to override them.

CONTROLLER

The Really Useful Group Limited is the controller and responsible for your
personal data (collectively referred to as “we”, “us” or “our” in this privacy
notice).

We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice. If you have any questions about
this privacy notice, including any requests to exercise your legal rights (see
below), please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

Full name of legal entity: The Really Useful Group Limited

Name of data privacy manager: Adam Brown

Email address: adam.brown@reallyuseful.com

Postal address: 6 Catherine Street, London WC2B 5JY

You have the right to make a complaint at any time to the Information
Commissioner’s Office (the “ICO”), the UK supervisory authority for data
protection issues (https://ico.org.uk). We would, however, appreciate the chance
to deal with your concerns before you approach the ICO so please contact us in
the first instance.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 25 May 2018.

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and
applications. Clicking on those links or enabling those connections may allow
third parties to collect or share data about you. We do not control these
third-party websites and are not responsible for their privacy statements. When
you leave our website, we encourage you to read the privacy notice of every
website you visit.

‍


2. THE DATA 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/or transfer different kinds of personal data
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 postal address, email address and telephone numbers.
 * Transaction Data includes details about products and services you have
   purchased from us, any of our group companies or from LW Theatres or any of
   its group companies (or any licensee of the foregoing) or any ticketing
   company.
 * 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 this website.
 * Profile Data includes your username and password, your interests,
   preferences, feedback and survey responses and information about your ticket
   lottery or audition applications (where relevant).
 * Usage Data includes information about how you use our website.
 * Marketing and Communications Data includes your preferences in receiving
   marketing from us and our third parties and your communication preferences.

We also collect, use and share 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 or indirectly 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 Aggregated 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.

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.

‍


3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

 * Direct interactions. You may give us your Identity Data, Contact Data,
   Transaction Data, Profile Data and/or Marketing and Communications Data by
   filling in forms or by corresponding with us by post, phone, email or
   otherwise. This includes personal data you provide when you:
 * create an account on our website;
 * subscribe to any of our mailing lists;
 * request marketing to be sent to you;
 * enter a competition, promotion or survey;
 * give us some feedback;
 * enter any ticket lottery; or
 * take part in any audition process.
 * Automated technologies or interactions. As you interact with our website, we
   may automatically collect Technical Data and/or Usage Data about your
   equipment, browsing actions and patterns. We collect this personal data by
   using cookies, server logs and other similar technologies. We may also
   receive Technical Data about you if you visit other websites employing our
   cookies. Please see our cookie policy for further details.
 * Third parties or publicly available sources. We may receive personal data
   about you from various third parties and public sources as set out below:
 * Technical Data from the following parties:

(a)  analytics providers;

(b)  advertising networks; and

(c)  search information providers.

 * Identity Data, Contact Data, Transaction Data and/or Marketing and
   Communications Data from any of our group companies or from LW Theatres or
   any of its group companies (or any licensee of the foregoing) or any
   ticketing company (which, for example, may include personal data about
   tickets you have purchased to events or shows).
 * Identity Data and Contact Data from data brokers or aggregators.
 * Identity and Contact Data from publicly availably sources, such as Companies
   House and the Electoral Register.

‍


4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

 * Where we need to perform a 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 you have consented to us processing your personal data in order for us
   to send marketing communications to you. Please note, you have the right to
   withdraw consent to marketing at any time by contacting us at
   online_team@reallyuseful.com.

‍

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all the ways we plan
to use 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 online_team@reallyuseful.com 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 manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey (a) Identity Data
(b) Contact Data
(c) Transaction Dat
(d) Profile Data
(e) Marketing and Communications Data (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 or products/services from any of
our group companies or from LW Theatres or any of its group companies) To enable
you to partake in a prize draw, competition, complete a survey, enter a ticket
lottery or partake in any audition process.(a) Identity Data
(b) Contact Data
(c) Transaction Data
(d) Profile Data
(e) Usage Data
(f) Marketing and Communications Data (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our
products/services or products/services from any of our group companies or from
LW Theatres or any of its group companies, to develop such products/services 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) Identity Data
(b) Contact Data
(c) Technical 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(a) Identity Data
(b) Contact Data
(c) Transaction Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data
(f) Technical Data (a) Necessary for our legitimate interests (to study how
customers use our products/services or products/services from any of our group
companies or from LW Theatres or any of its group companies, to develop such
products/services, to grow our business and to inform our marketing strategy)
(b) Consent to send marketing communications to you To use data analytics to
improve our website, products/services, marketing, customer relationships and
experiences(a) Technical Data
(b) Transaction Data
(c) Profile Data
(d) Usage Data
(e) Marketing and Communications Data Necessary for our legitimate interests (to
define types of customers for our products/services or products/services from
any of our group companies or from LW Theatres or any of its group companies, 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 (such goods or services being those
provided by us, our group companies or by LW Theatres or its group
companies).(a) Identity Data
(b) Contact Data
(c) Technical Data
(d) Profile Data
(e) Usage Data
(f) Marketing and Communications Data (a) Necessary for our legitimate interests
(to develop our products/services or products/services from any of our group
companies or from LW Theatres or any of its group companies and grow our
business)
(b) Consent to send marketing communications to you

MARKETING

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising and we may offer you different
ways to manage your marketing preferences from time to time.

PROMOTIONAL OFFERS FROM US

We may use your Identity Data, Contact Data, Technical Data, Usage Data, Profile
Data and Marketing and Communications Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which
products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us (about products/services
provided by us, our group companies or by LW Theatres or its group companies) if
you have requested information from us or purchased products/services from us or
requested information or purchased products/services from any of our group
companies or from LW Theatres or any of its group companies (or any licensee of
the foregoing) or any ticketing company or if you provided us with your details
when you entered a competition or registered for a promotion or ticket lottery
or entered any audition process and, in each case, you have not opted out of
receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with
any company outside our or the LW Theatres’ group of companies.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any
time by following the opt-out links on any marketing message sent to you or by
contacting us at online_team@reallyuseful.com at any time.

Where you opt out of receiving these marketing messages, this will not apply to
personal data provided to us as a result of a product/service purchase,
product/service experience or other transactions.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see our cookie
policy.

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 us at online_team@reallyuseful.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. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.

 * Internal Third Parties as set out in the Glossary.
 * External Third Parties as set out in the Glossary.
 * Third parties to whom we may choose to sell, transfer, or merge parts of our
   business or our assets. Alternatively, we may seek to acquire other
   businesses or merge with them. If a change happens to our business, then the
   new owners may use your personal data in the same way as set out in this
   privacy notice.

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.

‍


6. INTERNATIONAL TRANSFERS

We store, process, transfer and share your personal data with Internal Third
Parties and External Third Parties. This will involve storing, processing,
transferring and sharing your personal data outside the European Economic Area
(EEA).

Whenever we transfer your personal data out of the EEA, we ensure a similar
degree of protection is afforded to it by ensuring we will only transfer your
personal data to countries that have been deemed to provide an adequate level of
protection for personal data by the European Commission.

Please contact us at online_team@reallyuseful.com if you want further
information on the specific mechanism used by us when transferring your personal
data out of the EEA.

‍


7. DATA SECURITY

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.

‍


8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

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.

In some circumstances you can ask us to delete your data: see Request erasure
below for further information.

In some circumstances we may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.

‍


9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in
relation to your personal data. These include the right to:

 * Request access to your personal data.
 * Request correction of your personal data.
 * Request erasure of your personal data.
 * Object to processing of your personal data.
 * Request restriction of processing your personal data.
 * Request transfer of your personal data.
 * Right to withdraw consent.

Further details are set out at the end of this privacy notice.

More information about these rights is available from the ICO website:
https://ico.org.uk.

If you wish to exercise any of the rights set out above, please contact us at
online_team@reallyuseful.com or contact our data privacy manager (Adam Brown) on
Adam.Brown@reallyuseful.com.

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

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.

‍


10. GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance any
potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities
by contacting us at online_team@reallyuseful.com at any time.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.

Consent means you have consented to us processing your personal data in order
for us to send marketing communications to you. Please note, you have the right
to withdraw consent to marketing at any time by contacting us at
online_team@reallyuseful.com.

THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in our group from time to time and LW Theatres and any of its
group companies from time to time.

EXTERNAL THIRD PARTIES

 * Service providers (acting as processors) who provide IT, system
   administration, data storage services or who run our ticket lottery or
   audition programmes.
 * Professional advisers (acting as processors) including lawyers, bankers,
   auditors and insurers who provide consultancy, banking, legal, insurance or
   accounting services.
 * HM Revenue & Customs, regulators and other authorities (acting as processors)
   who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold about
you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you
to have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the time
of your request.

Object to 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.

Request restriction of processing of your personal data. This enables you to ask
us to 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.

Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have chosen, your personal data in a
structured, commonly used, machine-readable format. 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.

Withdraw consent at any time where we are relying on consent to process your
personal data. 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.

‍


WEBSITE COOKIE POLICY FOR THE REALLY USEFUL GROUP LIMITED

(in accordance with the Privacy and Electronic Communications (EC Directive)
(Amendment) Regulations 2011 (SI 2011/1208))

INFORMATION ABOUT OUR USE OF COOKIES

Our website uses cookies to distinguish you from other users of our website.
This helps us to provide you with a good experience when you browse our website
and also allows us to improve our site. By continuing to browse the site, you
are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or
the hard drive of your computer if you agree. Cookies contain information that
is transferred to your computer’s hard drive.

We use the following cookies:

 * Strictly necessary cookies. These are cookies that are required for the
   operation of our website. They include, for example, cookies that enable you
   to log into secure areas of our website.
 * Analytical/performance cookies. They allow us to recognise and count the
   number of visitors and to see how visitors move around our website when they
   are using it. This helps us to improve the way our website works, for
   example, by ensuring that users are finding what they are looking for easily.
 * Functionality cookies. These are used to recognise you when you return to our
   website. This enables us to personalise our content for you and remember your
   preferences (for example, your choice of language or region).
 * Targeting cookies. These cookies record your visit to our website, the pages
   you have visited and the links you have followed. We will use this
   information to make our website and the advertising displayed on it more
   relevant to your interests. We may also share this information with third
   parties for this purpose.

Please note that third parties (including, for example, advertising networks and
providers of external services like web traffic analysis services) may also use
cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to
refuse the setting of all or some cookies. However, if you use your browser
settings to block all cookies (including essential cookies) you may not be able
to access all or parts of our site.

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