Data Privacy Notice
We are We Are Nations (trading as “We Are Nations”) with registered number VAT 294044106 and address 55 Loudoun Road, St. John's Wood, London NW8 0DL, United Kingdom. Our Data Protection Lead can be contacted at firstname.lastname@example.org. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”). The terms “Personal Data”, “Special Categories of Personal Data”, “Personal Data Breach”, “Data Protection Officer”, “Data Controller”, “Data Processor”, “Data Subject” and “process” (in the context of usage of Personal Data) shall have the meanings given to them in the Data Protection Legislation. “Data Protection Lead” is the title given to the member of staff leading our data protection compliance programme in lieu of a requirement for a Data Protection Officer.
What are your rights?
When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:
- The right to be informed of how your Personal Data is used (through this notice);
- The right to access any personal data held about you;
- The right to rectify any inaccurate or incomplete personal data held about you;
- The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy;
- The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
- The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.
You can exercise your right to access personal data held about you by emailing email@example.com with the subject line: “Subject Access Request”. When you submit a ‘subject access request’, you will need to provide confirmation of your identity by contacting us using the email address associated with your profile. This is provided free of charge and our response will be made within thirty (30) days unless our Data Protection Lead deems your request as being excessive or unfounded. If this is the case, we will inform you of our reasonable administration costs in advance and/or any associated delays, giving you the opportunity to choose whether you would like to pursue your request. If you believe we have made a mistake in evaluating your request, please see the section ‘ Who can you complain to? ’.
If you have questions about any of the rights mentioned in this section, please contact our Data Protection Lead at firstname.lastname@example.org.
Who is the Data Controller?
- If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
- If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. Please refer to their own privacy notices. For a list of Data Controllers that we process personal data for, the section below ‘ Third Party Interests ’.
What are the lawful bases for processing personal data?
Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:
- a) ‘your consent’;
- b) 'performance of a contract';
- c) 'compliance with a legal obligation';
- d) 'protection of your, or another’s vital interests';
- e) ‘public interest/official authority’; and
- f) 'our legitimate interests'.
What are We Are Nations’ ‘legitimate interests’?
Legitimate interests are a flexible basis upon which the law permits the processing of an individual’s personal data. To determine whether we have a legitimate interest in processing your data, we balance the needs and benefits to us against the risks and benefits for you of us processing your data. This balancing is performed as objectively as possible by our Data Protection Lead. You are able to object to our processing and we shall consider the extent to which this affects whether we have a legitimate interest. If you would like to find out more about our legitimate interests, please contact email@example.com.
About our processing of your data
We might collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
Identity Data such as names, usernames or similar; marital status; title; date of birth; sex and gender.
Contact Data such as addresses; email addresses and telephone numbers.
Financial Data such as bank account and payment card information.
Transaction Data such as information about payments and details of purchases you have made.
Technical Data such as IP addresses; login data; browser info; time zone; location; browser plug-ins; operating systems; platforms and other technology on the device used to access this website.
Profile Data such as usernames; passwords; security answers; purchases/orders; interests; preferences; feedback and responses to surveys, blogs and messages.
Usage Data such as analytics relating to how you use the website.
Marketing and Communications Data such as your preferences about receiving communications from us or third parties.
Special Categories of Data such as details about race or ethnic origins, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic or biometric data.
We also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data can be derived from your Personal Data but is not itself Personal Data as it cannot be used to reveal your identity. If Aggregated Data is ever used in combination with your Personal Data and becomes identifiable, it will be treated in accordance with this notice.
We Are Nations does not collect any Special Categories of Personal Data about you or any information about criminal convictions/offenses.
|Reference||What categories fo information about you do we process?||Why are we processing your data?||Where did we get your personal data from?|
|Fan Community Management (including sign-up mailing lists, chat rooms and forums)||
||If you join one of our fan communities, we will use your personal data to contact you with updates related to the subject of the mailing list or forums that you have subscribed to, as well as occasionally running competitions or other community events and offering exclusive content and offers to you. These messages and websites might contain cookies, web-beacons, unique identifiers or similar to monitor our marketing distribution. This processing is conducted lawfully on the basis of 'performance of a contract'.||Directly obtained at the point of sale.|
||Whenever we sell you a product, such as music, merchandise or tickets, we use your personal data in order to manage your order, process payments and make sure that you receive your products. This processing is conducted lawfully on the basis of 'performance of a contract'.||Directly obtained at sign-up.|
||If you are a current or previous customer - providing that you haven't opted-out before or since we collected your personal data - we may occasionally send you marketing related to the products that you purchased. These messages might contain cookies, web-beacons, unique identifiers or similar to monitor our marketing distribution. This processing is conducted lawfully on the basis of 'our legitimate interests'.||Directly obtained at the point of sale.|
||If you wish to contact us regarding an aspect of our service, including complaints or enforcing your consumer rights in relation to a product or service that we have sold you, we will use your personal data in order to investigate a claim, evaluate your needs and/or possibly take action, such as sending you a replacement product. This processing is conducted lawfully on the basis of 'performance of a contract'.||Directly obtained at the point of sale, and at the time of enquiry (if applicable)|
||If you are an employee of one of our European business partners, we may use your personal data to communicate with you and your business about achieving our respective business objectives. This processing is conducted lawfully on the basis of 'performance of a contract'.||Directly obtained from you or referred to us by one of yours or our partners.|
What happens if I refuse to give We Are Nations my personal data?
We process some personal information as part of a contractual relationship with a Data Controller. Any requests to restrict this type of processing should be forwarded to the Data Controller; they will be responsible for discussing your concerns and making any decisions.
What do we do with Cookies?
We use the following types of cookie:
- a) 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 and to use a shopping cart.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences.
- 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. Some of these are third party cookies which analyse website usage.
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website and the advertising displayed on it more relevant to your interests. This information is anonymous and cannot identify you personally, but we may share it with third parties to help tailor advertising to your particular interests.
You can block cookies by activating settings on the website browser that you are using. However, if you use the settings to block all cookies (including essential cookies) you may not be able to fully access all areas of our website.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org.
What profiling or automated decision making does We Are Nations perform?
We Are Nations does not perform any profiling or automated decision making based on your personal data.
How long will your personal data be kept?
We Are Nations holds different categories of personal data for different periods of time. Wherever possible, we will endeavour to minimise the amount of personal data that we hold and the length of time for which it is held.
- If we process your data on the basis of ‘legitimate interests’, we will retain your data for as long as the purpose for which it is processed remains active. We review the status of our legitimate interests every twelve (12) months and will update this notice whenever we determine that either a legitimate interest no longer exists or that a new one has been found.
- All categories of personal data that are held by us because they are essential for the performance of a contract, will be held for a period of two (2) years, as determined by statute of limitations for Texas for the purposes of exercising or defending legal claims.
Who else will receive your personal data?
We Are Nations passes your data to the third parties listed in the section ‘Third Party Interests’ below.
Does your data leave the EU?
Yes. Details are included in the section ‘Third Party Interests’ below.
Third Party Interests
|Name/Category of Third Party Controller||What processing are we performing for them?||If applicable - who is their representative within the EU?|
|Client Controllers||We provide the services outlined above (‘Ecommerce Sale’, ‘Fan Community Management’ and ‘Customer Services’)||N/A|
|Regulatory authorities||We are joint Controller with these authorities who require reporting of processing in some situations.||N/A|
|Ticketing Partners||We provide ticketing services alongside certain ticketing providers. We will always keep you informed at the point of sale where your data is being shared with another company.||N/A|
|Postal/courier providers||Where these providers act as Data Controller, we are joint Controller with them for the purposes of order fulfilment||N/A|
|Payment Services Provider||We use these providers so that we can take electronic or card payments securely and without the requirement for you to disclose this data to us||Please refer to the Privacy Notices of the specific payment provider applicable to your service.|
Our Data Processors
|Name/Category of Third Party Controller||Purposes for carrying out processing||If applicable – where does data leaving the EEA go and what safeguards are in place?|
|Web hosting providers||Website hosting, including the storage of data forming the website content and processing your Technical Data (and Profile Data, where applicable) in order to provide you with access to our websites.||In the interests of providing a quality service, we use providers located in the United States. These providers are either Privacy Shield certified or bound by the contractual provisions of the EU Commissions model clauses.|
|Internal technology providers||
||In the interests of providing a quality service, we use providers located in the United States. These providers are either Privacy Shield certified or bound by the contractual provisions of the EU Commissions model clauses.|
|Marketing technology providers||Providers who enable us to send you our marketing emails and push targeted web advertising.||In the interests of providing a quality service, we use providers located in the United States. These providers are either Privacy Shield certified or bound by the contractual provisions of the EU Commissions model clauses.|
Who can you complain to?
In addition to sending us your complaints directly to firstname.lastname@example.org, you can send complaints to our supervisory authority. As We Are Nations predominantly handles the personal data of UK nationals, our supervisory authority is the Information Commissioner’s Office. If you believe that we have failed in our compliance with data protection legislation, complaints to this authority can be made by visiting https://ico.org.uk/concerns/.