Privacy Policy (ASM Global European Region)

ASM Global takes your privacy very seriously and we ask that you read this privacy notice carefully as it contains important information on:

• The personal information we collect about you;
• What we do with your information; and
• Who your information might be shared with.

This privacy notice explains how we use your personal data in order to improve our services to you, and what choices you have about how we use that data. This privacy notice has been written to comply with the new privacy laws, known as the ‘GDPR’ (General Data Protection Regulation).

When we refer to ‘we’ or ‘us’ or ‘ASM Global’ in this notice, we mean the venue operating entities of the European Region of ASM Global (comprised of a group of companies including AEG Facilities (UK) Limited, SMG (UK) Limited, SMG Europe Holdings Limited, and other associated companies (“the Group”)). The venues we operate and their respective contact details are listed in the Appendix at the end of this policy.

The Information We Gather

As a Group we may gather certain information about you when you register with us, purchase products or services from us, when you contact us, send us feedback, post material to our websites or social media channels, complete customer surveys or take part in promotions or competitions run by us. This information may also be shared with and/or used by certain other parties in connection with the event, such as our ticketing agents, social media agency, website hosting companies, security provider and event promoters, promoter ticket agents and affiliates. In addition, and provided you consent, your information may be shared with certain other parties for the purpose of marketing goods and/or services to you. These parties may include event promoters, resident orchestras (please see The Bridgewater Hall section in the Appendix for further information), venue sponsors, our social media agency, mailing houses and email server providers.

We will not sell any of your personal information to third parties, nor will we transfer your personal data outside of the European Union without your prior consent.

Information that we gather about you may include (without limitation) your name, contact details, date of birth, payment details, and accessibility and dietary requirements.

We may also obtain information about you from third parties, such as credit reference agencies, ticketing agencies, event promoters and Venue sponsors. Please be aware that our website and social media platforms contain links to third party websites and social media platforms. We are not responsible for the security or privacy policies of those third party sites, and recommend that you review those parties’ privacy notices before sharing your personal data on those platforms.

Reasons for processing

We process information about you for the following reasons:

• providing services to you;
• carrying out customer profiling and analysis of purchasing preferences;
• marketing our business and service and those of our partners which we believe will be of interest to you;
• operational reasons, such as recording transactions, training and quality control;
• improving our services;
• providing customer service;
• analysing customer feedback;
• investigating complaints;
• ensuring business policies are adhered to;
• tracking activity on our website and social media channels;
• to contact you in the event any products or services you requested are unavailable or to notify you in the event of any changes to an event;
• to personalise and improve your experience on our website and social media channels;
• to personalise any communications to you;
• compliance with legal, regulatory and corporate governance obligations and good practice; and
• gathering information as part of investigations by regulatory bodies or in connection with legal proceedings or requests.

When you use our website and social media channels we may also collect certain information about you and your visit to help us to improve your experiences on those platforms. This may include:

• your journey through our website and social media channels;
• what content you like or share;
• which pop up or push messages you saw and responded to;
• your IP address; and
• your browser type and operating system.

We may also collect personal information when you purchase a ticket for any of our events from our ticketing partner in order to assist us with event planning activities and to enable us to contact you with details of any changes to the scheduled event. We may keep a record of your name address, delivery details, e mail address, telephone number and bank details. In addition, we record CCTV images of you when you are at the venue or within its vicinity for your safety and security. CCTV images may be shared with the police for the purposes of crime prevention and detection.

Disclosures and exchange of information

We may disclose and exchange information with group companies, credit reference agencies, ticketing agencies, promoters, service providers, representatives and agents, as well as with law enforcement agencies and regulatory bodies for the above reasons.

Information may be held at our offices and those of our group companies, ticketing agents, promoters and third party credit reference agencies, service providers, representatives and agents as described above.

Some of the third parties with whom we share your data may be based outside the United Kingdom or European Union. If we do transfer your personal data outside the EU, we will take proper steps to ensure your personal data is transferred and held securely and in accordance with this privacy policy.

Children

On occasion we may collect limited personal data relating to children under the age of 16, for instance the names of attendees or participants in Learning and Participation or other educational events at certain venues. If you are a parent or guardian of a child under the age of 16 and think that we may have information relating to that child, please contact us at the relevant venue, using the details provided in the Appendix to this document. We will ask you to prove your relationship to the child but if you do so you may (subject to applicable law) request access to and deletion of that child’s personal data.

Sensitive personal data

You may also supply us with sensitive personal data relating to your physical health which is gathered for the purposes of ensuring easy access to our venue (in the case of people with accessibility requirements) or compliance with food safety (in the case of strict dietary requirements).

Keeping your data secure

We have appropriate security measures in place to prevent your personal information being accidentally lost, or used or accessed in an unauthorised way. We also limit access to your personal information to those who have a genuine business need to know it. Some of the technical and organisational measures we use to safeguard your personal data are:

• storing your personal data, in all forms, in a secure environment;
• training our staff on the importance of data protection measures;
• employing SSL (secure sockets layer) encryption on every domain owned by us – this allows us to encrypt any passwords and debit/ credit card information to prevent unauthorised access or disclosure;
• securing our network by an advanced firewall supported by industry standard anti-virus software.

We also have policies and procedures in place to deal with any suspected data breach so that we can act quickly to minimise any potential damage.

Your Rights

Under the GDPR you have a number of important rights. Those include:

• Right to fair processing of information and transparency over how we use your personal information – we are required to inform you why we want to gather your personal information, what we will do with it, who it will be shared with and how long it will be kept for. That information is set out in this privacy notice, but if you require any further information please don’t hesitate to contact us.
• Right to request a copy of your information – you can request a copy of your information which we hold (this is known as a ‘subject access request’). If you would like a copy of some or all of this information please contact us with proof of your identity and let us know what information you would like. We must provide this information to you in a commonly used and machine readable format.
• Right to require us to correct any mistakes in your information – you can require us to correct any information which we hold. If you would like to do this, please contact us to let us know the information that is incorrect and what is should be replaced with.
• Right to ask us to stop contacting you with direct marketing – you can ask us to stop contacting you for direct marketing purposes at any time. If you would like to do this, please contact us and let us know what method of contact (one or all) you are not happy with.
• Right to restrict processing – you can ask us to suspend the processing of your personal data in certain circumstances, for example, if you have notified us there is a mistake in the information we hold about you, you may ask us to suspend processing until that mistake is rectified.
• Right to erasure – otherwise known as ‘the right to be forgotten’ – you can ask us to delete or remove your personal data from our systems where there is no compelling reason for us to continue processing it.

If you want to exercise any of these rights, please write to us at the relevant venue, using the details provided in the Appendix to this document, and provide us with enough information to enable us to confirm your identity. We may also require proof of your identity, such as a copy of your driving license, passport and a recent utility bill or bank statement, to be sure that we are not releasing any of your personal data to anyone other than you.

Changes to this privacy notice

This privacy notice was first published on 30 April 2018 and last updated on 1 October 2019.

Your privacy is important to us and we are constantly reviewing our policies and procedures to ensure we are meeting the high standards we set ourselves. As a result, we may amend this privacy notice from time to time, and we recommend that you check this page periodically to review any changes that may have been made.

How to contact us

If you have any questions or concerns about this privacy notice or the information we hold about you, please do not hesitate to contact the relevant venue, as detailed in the Appendix, or the ASM Global European Region Headquarters by one of the following methods:

By post: Privacy Enquiries, ASM Global (European Region), 4^th Floor, Arena Point, 1 Hunts Bank, Manchester, M3 1UN

• By e mail: privacy@eu.asmglobal.com
• By phone: +44 (0)161 950 5114

If you would like this notice in another format (for example, audio, large print, braille) please contact us using any of the methods above.

If you have a complaint, we hope that we can resolve any issues you have by contacting us via one of the methods above. However, you also have the right to lodge a complaint with the Information Commissioners Office who may be contacted at https://ico.org.uk/concerns/ or via the helpline: 0303 123 1113.

APPENDIX: OUR VENUES

The following is a list of the venues currently operated by the ASM Global European Region. If you have any questions or concerns about the information one of our venues may hold about you, please do not hesitate to contact them using any of the methods also listed below.

Venues operated by SMG Europe Holdings Limited (registered number: 5558259): first direct arena

How to contact first direct arena:

• By post: first direct arena, Arena Way, Leeds, LS2 8BY
• By e mail: privacy@eu.asmglobal.com
• By phone: 0113 386 3600