PRIVACY POLICY
About us
KK Events Limited (“KK Events”) operates the Killing Kittens services, which include operating the Killing Kittens website at www.killingkittens.com (“Site”), carrying out administrative services for the separate Killing Kittens private members’ association (“Association”), organising live parties and other events for members of the Association (“Events”) and providing any other services under the Killing Kittens brand (collectively the “Services”).
KK Events is an English company (No: 14455293) with its registered office at 12 Hallmark Trading Estate, Fourth Way, Wembley, England, HA9 0LB.
The Association is an unincorporated association.
For the purposes of applicable UK and EU data protection laws, KK Events and the Association are responsible for processing your personal data in connection with this Privacy Notice as joint controllers. In this Privacy Notice, references to “we”, “us” and “our” are references to KK Events and the Association collectively, unless the context dictates otherwise.
About this Privacy Notice
This Privacy Notice (“Privacy Notice”) sets out how we process your personal data in connection with the Services. We are committed to protecting the privacy of all users of the Services and we aim to provides a safe and secure environment for your personal data.
This Privacy Notice is intended to assist you in making informed decisions when using the Services and should be read in conjunction with our Cookie Notice. Please take a moment to read and understand these documents. We recommend that you pay particular attention to the sections that explain Your rights as a data subject and how you can exercise those rights.
This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services. This includes, for example, where you follow links to third-party websites over which we have no control, or you purchase goods or services from those third parties.
Please note that your access to and use of our Site is also subject at all times to our Terms of Use. Your membership of Killing Kittens, including the purchase of tickets for Events that we host and your attendance at those Events, is subject at all times to the Membership Terms.
Please note that we sell tickets for our Events through our third-party ticket partners. When you access the online services of those third-party ticket partners, you are subject to the terms and conditions and privacy notices that apply to those services. However, all Events are organised by us (not the third-party ticket partner) and we are solely responsible for the organisation and operation of those Events. When you purchase an Event ticket, you are purchasing the ticket from us and you will be required to agree to the Membership Terms as a condition of making the ticket purchase.
Changes to this Privacy Notice
We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data. If we update this Privacy Notice, we will update the “last updated” date at the bottom of this page.
How to contact us
If you have any questions about this Privacy Notice or want to exercise Your rights as a data subject, you can contact us using the following methods:
Send us an email at: parties@killingkittens.com
Post
Write to us at: 2-6 Boundary Row, London SE1 8HP.
What personal data we collect
In providing the Services, we may collect and process different types of personal data about you for different processing purposes. When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance. The types of personal data we collect depends on who you are and how you use the Services. It will include the following:
Identity Data
First name; last name.
Contact Data
Home address; email address; telephone number; billing address
Membership Data
Personal data provided by you when you apply to the Association to become a Killing Kittens member, including: first name; last name; date of birth; gender; country; nationality; any other personal data that you may provide in connection with your application.
Verification Data
Your image/photograph, telephone number, government-issued passport or driving licence and any other personal data that we may request from you in connection with the verification of your application to the Association to become a Killing Kittens member or in connection with your attendance at an Event as a guest.
Profile Data
Personal data provided by you for your membership profile, including: your image/photograph; description of yourself; description of your body; sexual preferences and interests; profession; relationship status.
Guest Data
Personal data provided by you or by a member on your behalf when you are invited to attend an Event as a guest, including: first name; last name; date of birth; gender;
Message Data
Any personal data about you contained in messages sent and received by you and other Killing Kittens members in any private Killing Kittens group or page on a third-party platform.
Transaction Data
Details about purchases you have made from us, including details of your Killing Kittens membership, purchases of Event tickets, attendance at Events, waiting list status and payments made in respect of those purchases.
Financial Data
Bank account details; partial payment card details.
Observed Data
Data that is observed about your use of our Site or interaction with our emails and/or data that we infer through your use of our Site. This data may include details of when your current or previous sessions started; the referrer URL (web page that you were on when you clicked a link that sent you to our Site); information about the pages of our Site that you have visited and Services that you have purchased or shown an interest in.
Technical Data
IP address; browser type and operating system; general geolocation derived from your IP address, to ensure we’re showing you the correct notices and information; any other unique numbers assigned to a device.
Recruitment Data
Date of birth; gender; country; nationality; CVS; work experience; dietary requirements; any other personal data you may provide in advance of/during your supply of services to us.
Communications Data
Marketing communication preferences; service communication preferences.
How we collect and receive personal data
We collect and receive personal data using different methods:
Personal data you provide to us
You may give us your personal data directly, for example, when you provide your Membership Data to register as a Killing Kittens member; provide your Contact Data as part of a survey; purchase Event tickets; contact us with enquiries; complete forms on our Site; subscribe to receive our marketing communications; or provide feedback to us.
Personal data we collect using cookies and similar technologies
When you access and use our Site, we will collect certain Observed Data and Technical Data. We collect this personal data by using cookies and other similar technologies (see the Insight and Analysis section for more information).
Personal data received from third parties
We may receive personal data about you from third parties, including our analytics providers, data brokers and third party directories.
Publicly available personal data
From time to time, we may collect personal data about you (Identity Data and Contact Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example, through posts on social media platforms).
Who we collect personal data about
We collect and process personal data from the following people:
Site visitors
If you browse our Site, we will collect and process your personal data in connection with your interaction with us and our Site.
Killing Kittens members
If you apply to the Association to become a Killing Kittens member or purchase Event tickets, we will collect and process your personal data in connection with the provision of the Services.
Event attendees (members and guests)
If you attend an Event, whether as a Killing Kittens member or as a guest of a Killing Kittens member, we will collect and process your personal data in connection with the hosting and administration of the Event.
People who contact us with enquiries
If you contact us with an enquiry, submit a complaint or provide any feedback, we will collect and process your personal data in connection with your interaction with us and our Site.
People who work for our suppliers
If you work for one of our suppliers and have responsibility for administering your organisation’s account with us or handling our orders or our account with your organisation, we will process your personal data in connection with your organisation’s relationship with us.
Visitors to our physical locations
If you attend one of our offices, venues or other locations, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when asking us to assist you in finding accommodation or transportation suitable for your needs, or when signing in as a guest. CCTV footage may also be collected for security purposes.
Job applicants
If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.
How we use your personal data
We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
A: USE OF OUR SITE
If you browse our Site
When you browse our Site, we collect and process Observed Data and Technical Data to help us understand how you are using and navigating our Site. We do this so that we can better understand which parts of our Site are more or less popular and improve the structure and navigation of our Sites.
Our legal basis for processing: It is in our legitimate interest to use personal data in the ways described above to ensure that we provide access to our Site in a secure, safe and effective way and so that we can make improvements to our Site or it is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services.
If you use any interactive features on our Site
We will collect and use personal data about you when you use certain interactive features on our Site, such as our Chat. Depending on the nature of your enquiry, we may process your Identity Data, Contact Data and certain Observed Data and Technical Data when you get in touch with us in this way.
Our legal basis for processing: It is in our legitimate interest to use personal data in the ways described above to ensure that we can respond to your enquiries, provide access to our Site in a secure, safe and effective way and to make improvements to our Site.
If you link to social media sites and/or interact with our social media pages
If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on Twitter or Instagram or YouTube (including interacting with any “like” or similar embedded features on our Site or social media accounts), we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Observed Data and Technical Data. For more information about how we use this personal data, please see the Insight and Analysis section.
The relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.
Our legal basis for processing: It is in our legitimate interest to use personal data in the ways described above to ensure that we provide the Site in an effective way and to promote our Site via social media.
B: FULFILMENT OF THE SERVICES
If you apply to the Association to become a Killing Kittens member
You must apply to the Association to become a Killing Kittens member and to gain access to membership benefits such as the ability to attend our Events.
When you apply, you will be asked to provide all Membership Data (which is mandatory) as well as certain Profile Data (which is optional), Transaction Data and Financial Data. We will use this data for the purpose of processing your application, setting up your Killing Kittens membership, processing membership payments and for related membership record-keeping purposes.
We will use your Identity Data, Contact Data and Communications Data to send you any information and content you are entitled to under your membership and any service-related messages about your membership or any aspect of the Services we are providing to you, including in relation to any auto-renewal reminders.
Our legal basis for processing
It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or the legitimate interest of others to use personal data in the ways described above to ensure that we provide access to the Services in a secure, safe and effective way and so that we can make improvements to the Services.
If you provide any special (or “sensitive”) categories of data, such as data concerning your health, sex life or sexual orientation, we will only process that personal data where we are able to do so under applicable legislation (for example, where you have chosen to make that information public) or with your explicit consent.
If you purchase Event tickets from us
We collect and maintain personal data that you submit to us (including through our third-party ticket partners) for the purpose of supplying Event tickets. The personal data we process may include your Identity Data, Contact Data, Membership Data, Guest Data, Transaction Data and Financial Data (where applicable). We process this information so that we can check your eligibility to attend our Events, to provide the tickets to you, to maintain the Killing Kittens membership databases and to keep a record of how the Services are being used.
Please note that we sell tickets for our Events through third-party ticket partners. When you access the online services of those third-party ticket partners, you are subject to the terms and conditions and privacy notices that apply to those services. However, all Events are organised by us (not the third-party ticket partner) and we are solely responsible for the organisation and operation of those Events. When you purchase an Event ticket, you are purchasing the ticket from us and you will be required to agree to the Membership Terms as a condition of making the ticket purchase.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest or the legitimate interest of others to use personal data in the ways described above to ensure that we provide the Services in a secure, safe and effective way.
If you purchase other Services from us
We collect and maintain personal data that you submit to us for the purpose of supplying other paid Services. The personal data we process may include your Identity Data, Contact Data, Membership Data, Transaction Data and Financial Data (where applicable). We process this information so that we can fulfil the supply of the Services and to keep a record of how the Services are being used.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you for the Services, or it is in our legitimate interest or the legitimate interest of others to use personal data in the ways described above to ensure that we provide the Services in a secure, safe and effective way.
If you attend one of our Events
If you attend an Event as a Killing Kittens member, we will process your Identity Data, Contact Data, Membership Data, Profile Data, Communications Data, Transaction Data and any other relevant personal data to communicate with you about the Event, to provide tickets for the Event, to verify your identity and eligibility to attend the Event, to record your attendance at the Event, to monitor compliance with the Membership Terms (including our Code of Conduct) and for related record-keeping purposes.
If you attend an Event as a guest of a Killing Kittens member, we will process your Guest Data to verify your identity and eligibility to attend the Event, to record your attendance at the Event, to monitor compliance with the Membership Terms (including our Code of Conduct) and for related record-keeping purposes.
We may use Identity Data, Contact Data, Communications Data and Guest Data (if applicable) to contact Event attendees following an Event if we need to get in touch about any health and safety matters or legal issues. In the case of any incidents occurring at an Event, we may provide your personal data to the police or other authorities where necessary or desirable to cooperate with any investigation.
Event attendees may (where informed in advance) feature in photographs and other audio-visual content recorded at our Events. We may also ask you to provide quotes, testimonials and other interview content at an Event. Such content may appear in our advertising and marketing materials, including on our Site and in any membership emails and other publicity sent to the Killing Kittens membership database.
Our legal basis for processing: It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or or the legitimate interest of others to use personal data in the ways described above to ensure that the Event is operated in a secure, safe and effective way and in accordance with the Membership Terms and applicable laws.
Where we specifically ask your permission to use photographs and other audio-visual content featuring you or referring to you, or you provide quotes, testimonials or other interview content, our processing of your personal data will be based on consent.
If we are required to provide your personal data to the police or other authority in connection with any incidents occurring at an Event, we will do so in order to comply with our legal obligations, or it is it is in our legitimate interest or the legitimate interest of others to do so.
If we need to verify you
In certain circumstances, we may need to carry out additional identity verification in connection with your Killing Kittens membership application or your attendance at an Event. This helps us in our efforts to ensure that all Event attendees are eligible to attend, membership applicants are real people (not bots) and more generally to help ensure the safety of our community. You must provide the Verification Data and complete all mandatory verification steps to complete the verification process.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or the legitimate interest of others to use personal data in the ways described above to ensure that we provide access to the Services in a secure, safe and effective way and so that we can make improvements to the Services.
If you join a private Killing Kittens group or page on a third-party platform
From time to time, we run private chat groups or pages on third-party platforms. These private chat group and pages are only open to Killing Kittens members and access to the relevant group or page will only be granted subject to our prior approval. As the group or page administrator, we will process your Membership Data to confirm your Killing Kittens membership and determine your eligibility to join the relevant group or page.
We do not routinely monitor Message Data on Killing Kittens groups or pages, but we may do so in response to any complaint about you or your Message Data. In these circumstances, we will process your Message Data and certain Membership Data, Profile Data and any other relevant personal data collected by us or provided to us by you or third parties in connection with our investigation. We may use your personal data to assess what steps to take, which may include the suspension or termination of your access to our Killing Kittens group or page and/or your Killing Kittens membership.
Please note that the third-party operator of the platform hosting our Killing Kittens group or page will also be a separate independent data controller in respect of any processing undertaken by that third party in relation to your account with that platform and any content you post to that platform. Please see the relevant platform’s own privacy notice for more information about how they process your personal data and about your rights as a data subject.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or the legitimate interest of others to use personal data in the ways described above to ensure that we provide access to the Services in a secure, safe and effective way.
If you complete our surveys or provide feedback on your experience of the Services
From time to time, we will invite you to provide feedback about us and the Services. This will include post-Event surveys to find out more about your experience of the Event. We will collect and process your Identity Data and Contact Data as well as any other personal data you choose to volunteer in your survey response or other feedback.
We use this information to help us to monitor and improve the Services, to assist with the selection and development of future Services and to train our personnel.
You can also voluntarily provide feedback by email or via our Website Enquiry Form.
Our legal basis for processing: It is in our legitimate interest to use the personal data provided by you in the ways described above so that we can improve the Services and provide them in a secure, safe and effective way.
If you participate in one of our promotions
From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Membership Data and any other personal data volunteered by you in relation to your promotion entry.
Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g., the promotion terms and conditions) or it is in our legitimate interest to use your personal data in the ways described above to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of prize promotions.
If you participate in one of our promotions
From time to time, we may run prize draws, prize competitions and other promotions on our Site and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data, Membership Data and any other personal data volunteered by you in relation to your promotion entry.
Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.
Our legal basis for processing: It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g., the promotion terms and conditions) or it is in our legitimate interest to use your personal data in the ways described above to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of prize promotions.
If you have a general question or need help with any issue concerning the Services
There are various ways in which you are able to contact us. See the How_to_Contact_Us section for more information on contact methods.
When you make an enquiry, we will collect and process your Identity Data, Contact Data and certain Membership Data as well as any other personal data you volunteer that is relevant to your enquiry. We use this information to manage and respond to your enquiry.
If you have a technical issue concerning our Site, we may also collect and process Observed Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way.
Our legal basis for processing:It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our customer services.
If you breach the Membership Terms (including our Code of Conduct) or applicable law
If we have reason to believe that you are in breach of the Membership Terms or applicable law, we will process your Identity Data, Contact Data, Membership Data, Profile Data, Transaction Data, Guest Data (if applicable) and any other personal data collected by us or provided to us by you or third parties in connection with our investigation. This may happen, for example, if you breach our Code of Conduct at an Event or if we receive a complaint about you from another Killing Kittens member or Event organiser. We may use your personal data to assess what steps to take, which may include the suspension or termination of your membership and/or reporting any incident to the police or other authorities.
Our legal basis for processing: It is in our legitimate interest or the legitimate interest of others to use your personal data in the ways described above to ensure that we that we can provide the Services in a secure, safe and effective way.
If we are required to provide your personal data to the police or other authority in connection with any incidents occurring at an Event, we will do so in order to comply with our legal obligations, or it is it is in our legitimate interest or the legitimate interest of others to do so.
C: INSIGHT AND ANALYSIS
If we use cookies to help us personalise our Site and to understand more about users of our Site
We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) or may otherwise collect Observed Data through your use of our Site and any emails that you receive from us. Please see our Cookie Notice for further information, including details of our third-party partners.
We and our third-party partners use Observed Data and Transaction Data to personalise your experience on our Site and to personalise the content that we deliver to you through our advertising and marketing activities referred to in the Advertising and Marketing section.
In addition, we and our third-party partners may use Observed Data and Transaction Data on an aggregated basis, or in a way that does not directly identify you, for the following purposes:
to count users who have visited our Site or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve our Site and the Services and the effectiveness of our emails;
to measure the effectiveness of our content;
to learn what parts of our Site are most interesting to our users and what kind of features and functionalities our users like to see;
to help us understand the type of marketing content that is most likely to appeal to our clients and potential clients;
to help us with the selection of future service lines, website design and to remember your preferences; and
to understand the causes of errors and crashes in relation to our Site for troubleshooting and support purposes.
In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.
Our legal basis for processing: Where your data is collected through the use of non-essential Cookies, we rely on consent to collect your personal data and for the onward processing purpose. Please see our Cookie Notice for further details.
In certain circumstances, we may rely on another lawful basis when we use your personal data collected via the use of cookies. For example, where we use personal data collected through the use of analytics cookies to analyse how you use our Site, it is in our legitimate interest to use your personal data in the ways described above to improve the Services.
D: ADVERTISING AND MARKETING
This section describes how we may use your personal data to send our advertising to you (including to decide what advertising to send you). It also explains how we and our third-party advertising partners may use your personal data to display our advertising to you when you visit or use other websites and/or online services. In some cases, we may be joint controllers with third parties in respect of these activities – please see the Joint Controller Activities section below for further information on this relationship.
If we send you marketing communications by email and/or SMS
We use your Identity Data, Contact Data and Communications Data to send you marketing communications by post and/or email/SMS. Our marketing will include press releases and information about us, the Services, any events we may hold and the offers and promotions we offer from time to time.
Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you from Identity Data, Contact Data, Membership Data, Observed Data and Transaction Data. Non-personalised marketing is marketing that is not tailored to you.
Where we are sending you personalised marketing, we may also use Identity Data, Contact Data, Membership Data, Observed Data and Transaction Data to help us decide what sort of personalised marketing to send you. Please see the Insight_and_Analysis section for more details about how we may collect Observed Data.
Our legal basis for processing: It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.
It is in our legitimate interest to use your personal data to send our marketing to you by post. However, if you have expressly opted in to receive postal marketing from us, then our legal basis for sending postal marketing to you will be based on your consent. We will not send direct marketing to you by post if you have opted out of receiving postal marketing from us or you have otherwise registered with the Mailing Preference Service and you have not separately opted in to receive postal marketing from us.
We will only send marketing communications to you by email and/or SMS where we have permission to do so. For example, you may have opted in to receiving marketing on our Site or we may have collected permission to send you marketing when you enquired about or purchased the Services. In certain circumstances, we may rely on our legitimate interest to send marketing by email and/or SMS to those who have purchased or requested the Services.
In addition, please see the Insight_and_Analysis section to learn about the legal basis that we rely on to collect Observed Data via the use of Cookies.
If we carry out any online advertising through third-party advertising tools
Our third-party advertising partners may provide tools that we can use to display our ads to people who we think are more likely to be interested in the Services.
For example, an advertising partner may have determined that you are someone who is likely to be interested in cruise holidays, using data that they have collected about you (which we do not receive). If we want to display our advertising to people interested in such services on third-party websites that use the services of our advertising partner, we may ask our advertising partner to display our advertising to you.
Our legal basis for processing: If you are someone who has seen this advertising, it is in our legitimate interest that the relevant third-party advertising partner uses the data that you have provided to it to advertise the Services, although please note that we do not receive this data and you should exercise your data subject rights in accordance with the privacy notice of the relevant online service that displays our advertising to you.
If we carry out any online advertising through Observed Data
We and our third-party partners may also use Observed Data and other data that is collected through your use of and interaction with third-party websites and services to provide you with, and analyse the effectiveness of, personalised and non-personalised advertising when you visit or use those other websites and services. In some cases, we do this as described in the Customer Match Advertising section below.
By “personalised ads”, we mean advertisements for products and services that you have shown an interest in when you have used our Site or which we or our third-party partners think you otherwise might be interested in based on Observed Data. Our third-party partners may use the data that is collected to show personalised ads for products and services offered by third parties.
Our legal basis for processing: Please see the Insight and Analysis section to learn about the legal basis that we rely on to collect data via the use of Cookies.
Where we use your personal data to display personalised online advertising to you, we rely on the consent that you have provided in respect of the collection of such data, or it is otherwise in our legitimate interest to promote the Services to you.
Our third-party partners may rely on a different lawful basis in respect of their use of your personal data. For more information, please read the privacy notice of the relevant third-party provider (see our Cookie Notice for details).
If we carry out “customer match” advertising
We may share your Contact Data (usually your email address, in an encrypted or ‘hashed’ form) with third-party providers of social media platforms such as Facebook and other similar platforms (“Social Media Platforms”), so that the Social Media Platform can try to “match” your data with the registration data of their registered users.
Where there is a successful “match” (i.e., because you are a registered user of the relevant Social Media Platform), our advertising will be displayed to you when you use the relevant Social Media Platform (e.g., on your Facebook newsfeed). This is known as “customer match” or “custom audience” advertising because we “customise” the audience that we want to reach on the relevant Social Media Platform.
In some cases, we may also share your hashed Contact Data with Social Media Platforms in order to exclude you from seeing our advertising (because we are trying to reach people who are not yet users of the Services).
Some of the advertising that you see may be personalised to you. The data that we use to personalise our advertising, such as your Technical Data and Observed Data, will not be provided to the third-party providers of the Social Media Platforms. Please see the Insight and Analysis section to learn more about how we personalise advertising to you.
This activity is also subject to the privacy choices you have elected to make on the relevant Social Media Platforms.
Our legal basis for processing: We will only share your personal data with Social Media Platforms for the above purpose where you have provided your consent or where it is otherwise in our legitimate interest to do so to promote the Services.
If we carry out “lookalike” advertising on Social Media Platforms
Where we have displayed our advertisements to people on Social Media Platforms through Customer Match Advertising (as described above), we may also ask the relevant Social Media Platforms to find other people that share similar interests and characteristics to those persons, which will be based on information that the Social Media Platforms have collected about you and those similar persons (which we do not receive).
This is known as “lookalike” audience advertising because we are trying to show our advertising to people who “look like” our customers and users, and other persons that are likely to be interested in our advertising based on having similar characteristics or interests.
If you are someone who has seen our “lookalike” advertising on a Social Media Platform, this is because the Social Media Platform has determined that you “look like” our customers. Please note that this activity is based on data that you have provided to the relevant Social Media Platform (which we do not receive) and is also subject to the privacy choices you have elected to make on such third-party services. If you wish to opt out of receiving this form of advertising, you will need to update your preferences on the relevant Social Media Platform.
Our legal basis for processing: It is in our legitimate interest to share your personal data with the Social Media Platforms so that we can advertise the Services to other individuals that use those Social Media Platforms and share similar interests and characteristics with you. You can opt out of our sharing of your personal data with the Social Media Platforms by exercising your rights as a data subject as explained in the Your rights as a data subject section below.
If you are someone who has seen our “lookalike” advertising on a Social Media Platform, it is in our legitimate interest that the relevant Social Media Platform uses the data that you have provided to it to advertise the Services, although please note that we do not receive this data and you should exercise your rights in respect of such data in accordance with the privacy notice of the relevant Social Media Platform that displays our advertising to you.
E: RECRUITMENT ACTIVITIES
If we use your personal data in connection with our recruitment activities
We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.
The personal data we process may include your Identity Data, Contact Data, Applicant Data and any other personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.
We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.
We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.
Our legal basis for processing
Where we use your personal data in connection with our recruitment activities, it will be in connection with us taking steps at your request to enter into a contract with you, or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
G: RECEIPT OF PRODUCTS AND SERVICES FROM OUR SUPPLIERS
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business
We may use your personal data: (i) to comply with our legal obligations; (ii) to help prevent fraud; (iii) to enforce or protect our legal rights; (iv) to protect the rights and safety of third parties; and (v) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.
Our legal basis for processing: We have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order. Where we use your personal data in connection with a business transition, fraud prevention, to enforce or protect our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.
