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Spring of Culture Privacy Policy

 

Spring of Culture 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.

  1. IMPORTANT INFORMATION

PURPOSE OF THIS PRIVACY POLICY

This privacy notice aims to give you information on how Spring of Culture collects and processes your personal data through your use of this website, including any data you may provide through this website, such as when you sign up to our newsletter.

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 the other notices and is not intended to override them.

CONTROLLER

Spring of Culture is the controller and responsible for your personal data (collectively referred to as “Spring of Culture”, “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us

You have the right to make a complaint at any time, and we appreciate the chance to deal with your concerns before you approach the relevant authorities so please contact us in the first instance

CHANGES

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.

  1. THE DATA WE COLLECT ABOUT YOU  

PERSONAL INFORMATION COLLECTION

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).

Spring of Culture may collect and use the following kinds of personal information:

  • Information about your use of our website;
  • Information that you provide for the purpose of registering with or submitting information and documents to our website;
  • Information about communications carried out through this website;
  • Information that you provide for the purpose of subscribing to our website services and accessing information which includes but is not limited to, full name, phone number, email address, messages, images;
  • Any other information that you send to Spring of Culture;
  • Identity Data, including first name, maiden name, last name, marital status, title, date of birth, gender, nationality, place of residence, company, and position;
  • Contact Data, including email address, mailing address and telephone;
  • Technical Data, including 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;
  • Usage Data, including information about how you use our website, products and services; or
  • Marketing and Communications Data, including your preferences in receiving email communications from us (ex. newsletter, event announcements, industry insights, etc.) 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.
  1. 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 general personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    – apply for our services;
    – subscribe to our newsletter;
    – request marketing to be sent to you;
    – enter a survey; or
    – give us some feedback.
  • 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, server logs and other similar technologies.
  • 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 such as Google Analytics;

(b)  advertising networks such as Google & Facebook advertising networks; and

(c)  search information providers such as Google based outside the EU.
        – Identity and Contact Data from publicly available sources.

HOW WE USE YOUR PERSONAL DATA  

USING PERSONAL INFORMATION

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:

  • Administer this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • Personalise the website for you;
  • Enable your access to and use of the website services;
  • Supply services that you subscribe to, such as newsletters, industry insights and event announcements;
  • Perform the contract we are about to enter into or have entered into with you.
  • Where we need to comply with a legal or regulatory obligation, and in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend its legal rights;
  • 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; or
  • Send you marketing communications.

Where Spring of Culture discloses your personal information to its agents or sub-contractors for these purposes, the agent or sub-contractor in question will be obligated to use that personal information in accordance with the terms of this privacy statement.

OPTING OUT  

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 via email or text message. You have the right to withdraw consent and opt out to marketing communications at any time by contacting us here.

       4. DATA SECURITY

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information. 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.

Spring of Culture will store all the personal information you provide on its secure servers.

      5. CROSS-BORDER DATA TRANSFERS

Information that Spring of Culture collects may be stored and processed in and transferred between any of the countries in which Spring of Culture operates to enable the use of the information in accordance with this privacy policy.

You agree to such cross-border transfers of personal information.

Please contact Spring of Culture if you want further information on the specific mechanism used by us when transferring your personal data in any of the countries in which Spring of Culture operates.

    6. 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.

   7. UPDATING THIS STATEMENT

Spring of Culture may update this privacy policy by posting a new version on this website.

You should check this page occasionally to ensure you are familiar with any changes.

Spring of Culture’s details

You can contact Spring of Culture by using the contact form.

 

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