This privacy policy page was last updated on 7 June 2018.

INTRODUCTION

The ECC is committed to protecting the privacy of those who use our services; being transparent about what data we hold about you; and giving you control over how we use it.

The purpose of this policy is to give you a clear understanding of what information we collect about you, how we collect it (from you directly and from third parties), how we use it, and how we keep it secure. We are the data controller for your personal information and will ensure that it is stored and used in accordance with the EU General Data Protection Regulation (EU 2016/679).

WHO WE ARE

The ECC is a Belgian not-for-profit association (“ASBL”) registered as “The English  Comedy  Club,  Brussels” (or “ECC” in the abbreviated form), at 73 rue Waelhem, 1030 Schaerbeek, with the enterprise number 0409.491.834. CAST owns the building out of which the association operates. It is also a charitable organisation, registered in Belgium as “Cooperative Association to Support Theatre” (or “CAST” in the abbreviated form), at the above address, with the enterprise number 0452.838.758.

The information you provide, helps us to keep you informed about ECC’s activities and to deliver a better, more personalised experience and ticket buying process via our website. If you would like to update your contact information and preferences, you can do so:

By email: privacy@ecc.theatreinbrussels.com
By post: ECC Committee, 73 rue Waelhem, 1030 Schaerbeek, Belgique

HOW WE PROTECT YOUR DATA

We’re committed to protecting your personal information. We adopt appropriate technologies and policies to protect it from unauthorised access and improper use.

As part of the services offered to you through the ECC website, the personal information you provide may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen if any of the computer servers used to host the website are located in a country outside of the EEA. If the ECC transfers your personal information outside of the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected as outlined in this privacy notice.

The ECC may transfer your data to organisations based in the USA such as Facebook, Google or Mailchimp. The USA has weaker data protection laws than that of the EEA and therefore we will ensure that only organisations who are a part of the EU privacy shield initiative will handle your personal information. More details on this certification can be found at www.privacyshield.gov/welcome

HOW LONG WE KEEP YOUR DATA

We keep your information only for as long as is reasonably necessary for the purposes set out in this privacy notice and to fulfil our legal obligations. We will not keep more information than we need. The retention period will vary according to the purpose, for example if purchasing a ticket only, we will typically keep your data for up to 5 years from the date of your last point of engagement whereas if you have become a supporter or are a past or current member, we will hold your details indefinitely.

If you ask us to stop sending direct marketing communications to you, we will retain the information required (e.g. name, address or email address) to ensure we adhere with such requests.

YOUR RIGHTS

At any time, you have the right to ask the ECC to amend or to stop how it uses your personal information including for marketing purposes.

You can contact us by emailing or writing using our contact details set out at the top of this Privacy Policy.

Every email we send to you will include details on how to change your communications preferences or unsubscribe from future communications.

You can request full details of personal information we hold about you under the General Data Protection Regulation, by contacting us. Please send a description of the information you would like to see, together with proof of your identity to privacy@ecc.theatreinbrussels.com.

You also have the right to ask that information held about you by us is corrected and/or updated. If you have any concern about the accuracy of your personal data or if you would like us to remove the personal information we hold about you, please contact us using the contact details set out at the top of this Privacy Policy.

You have the right to lodge a complaint with the supervisory authority, which in Belgium is the Privacy Commission – https://www.privacycommission.be/fr/contact

If you are under 18, please ensure that you obtain your parent/guardian’s consent beforehand whenever you provide personal information to the website. If you don’t have that consent, you must not provide personal information to us.

WHAT INFORMATION WE COLLECT FROM YOU AND WHERE FROM

We collect your information when you interact with us. This could be when you sign up for our e-newsletter (ECCO), or when you book tickets, make a donation, take part in a workshop, event or project. These interactions may occur online, in person or over the phone.

We collect personal information when you:

• Sign-up to our e-mail list
• Update your communication preferences
• Make a donation
• Sign-up to participate in a project or workshop
• Purchase tickets
• Purchase tickets through a third party such as another theatre or ticket agent
• Visit our website
• Visit, follow, or leave comments on our social media pages

THE TYPES OF INFORMATION WE COLLECT

We only collect information that is necessary to deliver our community objectives, to provide the services that you have requested and to keep you informed about our activities. The more ways that you engage with us as an organisation, the more data we will need to deliver our services efficiently.

There are occasions where you can choose to not provide us with the information we require, but this may then impact the service we are able to provide to you.

If you are purchasing tickets:

• Full name
• Email address
• Payment card details (we never store your payment card data)
• Bank details for direct debit instructions
• Access requirements
• Delivery address(s)
• Billing address
• Contact preferences

Third Parties we work with

We may also obtain your data from third parties, such as organisations with which we enter into a co-production.  These organisations should not pass on your data to us without your knowledge and only if it is required in the performance of a contract.  The third party will require your permission in order to share your data with us for marketing purposes and we will always notify you within 30 days of receipt of your data.  You should check their Privacy Policy when you provide your information to understand fully how they will process and safeguard your data.

Social Media

Depending on your settings or the privacy policies for social media services like Facebook, Instagram, Twitter, YouTube, etc., you may give us permission to access information from those accounts or services, such as your behaviour on these services and across our site. The majority of this behaviour is anonymised. For more information on how to control your privacy settings for these services, go to the following links:

Facebook – Privacy Policy
Instagram – Privacy Policy
Twitter – Privacy Policy
YouTube – Privacy Policy

WHY WE COLLECT INFORMATION AND HOW WE USE IT

The main reason we collect information is to provide the service(s) you requested from us.

We also use personal information to contact you about our organisation based on your contact preferences, or to ensure that we are providing the best possible service. We will only contact you by email about non-contractual information where we have your consent to do so.

We collect personal information to:

• Carry out our business and to provide a service to you:
• To fulfil ticket, donation and membership requests
• To process payments
• Contact you with important information relating to your booking or purchase
• Provide the best possible customer service such as: confirming your order, reminding you of an upcoming booking, or letting you know about any show or venue changes that may affect your visit

Where we have your specific consent to:

• Send you updates via email about what’s on, and news about our organisation
• Email you about ways that you can support us

Where we have legitimate interest to:

• Learn about your interests and preferences so that we can contact you with information that is relevant to you
• Help us target our marketing and development communications and adverts so that they’re more relevant to you
• Send relevant invitations to events if we believe this would be of interest
• Use your anonymised details to show you advertising on social media platforms or via third party advertising that may appear on other websites you use (the information shared with these platforms is pseudonymised to protect your personal data)
• Classify our audience into groups or segments, using booking and publicly available information (these segments help us to understand our audience better and ensure we’re sending relevant messages to each group
• Measure and understand how audiences respond to our marketing activities so we can ensure they are well targeted, relevant and effective
• Analyse and continually improve the services we offer including our artistic output, our website and our other products
• Ensure we are maximising our ticket sales wherever possible

WHO WE SHARE INFORMATION WITH

The ECC will never share, sell, rent or trade your personal information to any third parties for marketing purposes without your prior consent.

We use a number of data processors in order to help us provide the services you request. These organisations are obligated to act on our instruction in relation to their use of your personal data and do not have any control over your data in their own right. We make sure anyone who provides a service for the ECC enters into an agreement with us and meets our standards for data security. They will not use your data for anything other than the clearly defined purpose relating to the service that they are providing.

Examples:

• Name on card, credit card number, billing address, CVV, amount of transaction and order number with our payment provider in order to process credit card transactions
• Name on bank account, bank account number, sort code, amount of direct debit, frequency and customer number with our payment handler in order to process direct debit transactions
• Sort code and account number with our merchant in order to complete modulus and know your customer checks
• Name and email address with Mailchimp in order to produce e-marketing campaigns, pre- & post-show emails
• We will only supply full name and email address in these data shares and only with your consent
• Third party advertisers (such as Facebook or Google) to help us identify customers similar to our audience or to serve adverts they deem relevant to you on third party websites. The information shared with these advertisers is pseudonymised to protect your personal data
• Our ticketing system provider (https://thelittleboxoffice.com) to enable us to sell tickets online, and to provide support and maintenance of our ticketing system
• When requested by the police or a regulatory or government authority investigating illegal activities

The ECC is not responsible for the privacy notices and practices of other websites even if accessed using links from our website and recommends that you check the policy of each website you visit and contact its owner or the Data team if you have any concerns or questions. While we take all possible precautions, no data transmission over the internet is 100% secure and we cannot guarantee the security of any information you disclose to us and so wish to draw your attention to the fact that you do so at your own risk.

More information

This policy may be updated to take into account changes we have made, or to reflect changes to regulation or legislation. Updates to this policy will be posted on this page – please check back from time to time. We may also inform you of any changes where we hold an appropriate email address for you.

Further information on data protection regulations and laws can be found here:

Data Protection information by the Privacy Commission in Belgium
Data Protection information by the Information Commissioner’s Office in the UK
You can contact us at any time to access the information we hold about you on privacy@ecc.theatreinbrussels.com.