Last Updated 02.08.2019
This Privacy Notice sets out the basis on which Secret Group companies will collect, use and share personally identifying information (‘Personal Data’) about users of our websites and about customers who purchase tickets for our events, attend our events, or subscribe to our newsletters and social media feeds.
For more information about Secret Group companies and the region(s) where they operate, as well as our websites, click here.
Our privacy commitments
We will only collect, keep, use and share Personal Data for legitimate business purposes that we explain here below, or if we’re legally required or allowed to do so.
We will be as clear and open as we can with you on what Personal Data we collect and how it will be used and shared.
For as long as we maintain records of your Personal Data, we will keep it up to date and protect it with appropriate safety measures.
Customers and Account Holders
We collect the following Personal data from or about you as a Secret Group customer:
Personal Data Collected Directly from you through the booking process for our events: your name, phone number, postal address, email address, gender and age. This enables us to provide the services you have purchased.
Personal Data Collected Automatically from the use by you of our websites. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. This enables us to operate our websites and provide you with access to the pages and functionality you wish to access.
Personal Data received Indirectly through our suppliers which enables us to create and store a record of your purchase history. The legal basis for collecting and processing this personal data is our legitimate interests in knowing more about our customers.
We use your Personal Data:
For the administration of your purchases and our events and to contact you about your purchase (for example with details on your tickets and your attendance).
To contact you with marketing messages which you have requested or agreed to receive from us (for example via a branded newsletter);
To contact you with surveys and feedback requests (for example relating to a show you attended);
To analyse the purchase history of our customers and the way our customers use our websites.
Google Analytics, a web analytics service provided by Google, Inc. (“Google”) also places cookies on your computer, to enable Google to provide us with reports relating to activity on our websites. Google uses this data only to provide us with information on how users use our websites and does not associate your IP address with any other data held by Google. The information generated by Google cookies (including your IP address) will be transmitted to and stored by Google on servers in the United States. You may refuse these cookies by selecting the appropriate settings on your browser or by downloading and installing the browser plug-in available under https://tools.google.com/dlpage/gaoptout?hl=en-GB.
Secret Group companies will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate our websites, provide our services to you and administer your account or otherwise as required or permitted by law.
We will share your Personal Data with social media sites to enable them to provide marketing messages that you have agreed to receive from them. The social media sites we share your Personal Data with as at the date of this Privacy Notice and their respective privacy statements are:
Snap Inc. (“Snapchat”), https://www.snap.com/en-US/privacy/privacy-policy/
When you purchase tickets for one of our events, you will be sent information to create an account for you to access more information about that event. Additionally, if you have opted to create a single Secret Cinema account to manage all your Secret Cinema activities, we will collect all your past and future event information in that single account.
We collect the following data from you as a Secret Group show guest:
Data Collected Directly: your name, email address, postal address, gender in the website registration process.
Data Collected Indirectly: your attendance history.
We use your Personal Data:
To contact you about your attendance (for example with your arrival time);
To contact you with future event marketing messages (for example with branded newsletters or an advertisement on Facebook);
To send you surveys or feedback requests (for example after you attended an event);
To find out more about our guests and their preferences (for example by analysing your attendance history).
Secret Group will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate our websites, and provide our services to you or otherwise as required or permitted by law.
Social Media Followers
We receive the following Personal Data about you if you follow one of our social media accounts: Your account name, gender, general interests, location, age. Our legal basis for processing this data is our legitimate interest in providing social media and marketing content that is of interest to our followers on social media.
We use this Personal Data:
to provide bespoke social media content (for example by analysing your general interests);
to create targeted advertising across all our social media channels (for example by analysing responses to posts and existing advertisements);
to find out more about our digital community (for example by analysing the age ranges of our followers).
Secret Group will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate our websites, provide our services to you and administer your accounts or otherwise as required or permitted by law.
Opting out of Social Media Ads
We use online adverts to promote our events and services to social media users on Facebook, Instagram, Twitter, and Snapchat. If you prefer not to see our adverts on these social media platforms, you can opt out using the following guides:
You can adjust your ad preferences for Facebook and Instagram on: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
You can adjust your ad preferences for Twitter on: https://twitter.com/settings/personalization
Find out how you can adjust your ad preferences on Snapchat on: https://support.snapchat.com/en-GB/a/advertising-preferences
Please note that to opt out of receiving marketing emails direct from Secret Group companies you will also need to use the unsubscribe link in the footer of our emails.
We collect the following Personal Data about you if you visit one of our websites: site referrals, browsing pattern, browser type, location, general interests, gender, age. The data transmitted from your browser includes your IP address, the date and time of the visit the pages accessed, the access status/ HTTP status code, your browser, your operating system and interface, as well as the language and version of the browser software. The legal basis for collecting and processing this personal data is our legitimate interest in operating our websites, providing you with access to the pages you wish to access, understanding the interests of our potential customers and providing you with relevant information about our services.
We use this Personal Data:
to provide you with bespoke website content (for example by analysing our site visitors’ age ranges);
to gain insight into your behaviour and preferences (for example by analysing the website pages you visit);
to create bespoke marketing messages (for example by analysing the click- throughs on our Sites);
to re-target our website visitors with relevant marketing messages (for example by using cookies hosted on our websites);
to collect site statistics.
For more information please see our Cookie Statement.
We use Facebook pixels on our pages. Pixels are lines of code placed on our website to help us track conversions from Facebook ads, optimise ads based on collected data, and build targeted audiences,
Secret Group will not sell your information. We will not share your information with any third party except as stated in this Privacy Notice or as required to operate our websites, provide our services to you and administer your account or otherwise as required or permitted by law.
We use third party processors to collect, export, process and store Personal Data on our behalf. The processors we use currently are the following:
Universe, https://www.universe.com. Located in the U.S. and Canada. Standard European Clauses have been signed.
Festicket. Located in the EEA. https://www.festicket.com/privacy-and-cookies/
Pollen. Located in the EEA. https://www.pollen.co/uk/privacy-policy
London Theatre Direct. Located in the EEA. https://www.londontheatredirect.com/privacy-policy
Fever Labs. Located in the US. Standard European Clauses have been signed. https://docs.google.com/document/d/e/2PACX-1vTPrFsSuFD7Bp_bvXbcsJCZXFm0mlir_-d9jhGDsG1TKIxrz2FsQQs448GFuE-RyrzmIS7gmOJVC7mx/pub?embedded=true
Stripe, located in the U.S. Privacy Shield Certified https://stripe.com/privacy-shield-policy
CRM Tool: Mailchimp. https://kb.mailchimp.com/accounts/management/about-mailchimp-the-eu-swiss-privacy-shield-and-the-gdpr
E-Commerce Tool: Shopify, https://www.shopify.com/legal/privacy
Microsoft Exchange, https://privacy.microsoft.com/en-GB/privacystatement
1and1 IONOS, https://www.ionos.co.uk/terms-gtc/terms-privacy
Social Media Platform: Facebook, some data centres located in the U.S. Privacy Shield Certified. https://www.facebook.com/privacy/explanation
Social Media Platform: Snapchat, some data centres located in the U.S. Privacy Shield Certified. https://www.snap.com/en-US/privacy/privacy-policy/
Survey Tool: Survey Monkey, located in the U.S. Privacy Shield Certified. https://www.surveymonkey.com/mp/policy/privacy-policy/
Web Management Tools
Squarespace, located in the U.S. Privacy Shield Certified. https://www.squarespace.com/privacy/
Google Analytics, located in the U.S. Privacy Shield Certified. https://www.google.com/policies/privacy/
AWS, located in the U.S. Privacy Shield Certified. https://aws.amazon.com/privacy/
Mimecast, located in the UK. https://www.mimecast.com/archived-pages/company/mimecast-trust-center/gdpr-center/privacy-statement/
Zapier, located in the US. Privacy Shield Certified. https://zapier.com/privacy/
International Data Transfers of Personal Data of EU citizens
We use data processors located outside the European Economic Area only after taking such steps as are required to ensure that Personal Data they process on our behalf receives protection equivalent to that provided in the EEA. Our processors are either certified as compliant with the EU-U.S. Privacy Shield Framework where they are located in the USA or have entered into an agreement with us containing the model clauses approved by the European Commission as providing contractual protection equivalent to that provided by the data protection regulations applicable in the EEA. To learn more about the Privacy Shield program, please visit www.privacyshield.gov.
For EU residents; Secret Group Limited is the Data Controller in respect of any Personal Data that you submit to us or that we collect from or about you. We are a limited company registered in England and Wales (registered no. 05071764) with registered offices at 7 Savoy Court, London WC2R 0EX.
For California residents; “Do Not Track” (DNT) has been promoted by US regulatory authorities for the internet industry to develop and implement a mechanism that allows internet users to control the tracking of their online activities across websites.
Secret Group currently does not respond to DNT browser signals.
We maintain technical and physical safeguards that are designed to protect the security and integrity of your Personal Data, and to guard it against accidental or unauthorised access, use, alteration or disclosure to unauthorised third parties. These measures include device encryption, firewalls and virus checking procedures.
Where we keep Personal Data files on local devices these devices are protected and accessible only to authorised Secret Group employees.
We regularly review our security systems to ensure that your Personal Data remains safe and secure.
Duration of Storage
We will maintain records of your Personal Data for as long as:
you remain a registered account holder, subscriber to our mailing list, or a registered user of any of our websites;
you have completed a purchase with Secret Group in the last 36 months; or
is necessary to provide our services to you.
If you have not opened any email communication from a Secret Group brand or interacted in any other way with our brands for 36 months we will regard you as an inactive subscriber and delete your details from our records except where retention is necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees.
Your Rights in Relation to Personal Data
You can update your subscription preferences or unsubscribe from our marketing communications at an time by following the link in the footer of the last email you received from one of our brands (“Update your subscription preferences” or “Unsubscribe”) or by sending your request with detailed instructions for our relevant Customer Services team.
You have the right to update and correct the personal information on your account. You may also have the right to request from us all personal information that we hold that relates to you, to request restriction of the processing of that data and to request that we delete that data. Where allowed by applicable law there may be an administrative charge for supply of copies of data and we may also require you to provide us with appropriate identification before we comply with this request. You also have the right to object to our continued processing of your personal data. You may also have the right to data portability. If you have a complaint about the way in which we use your personal information you have the right to complain to the relevant regulator in your jurisdiction.
You can contact us with questions about the personal information we hold about you using the contact information provided in the contact us section of this privacy notice.
Changes to our Privacy Notice
If you would like to know what information we hold about you or if you have any other queries or complaints in relation to this Privacy Notice, or our websites, our contact details are as follows: firstname.lastname@example.org
A superseded version of our Privacy Notice can be found here.