Privacy & Cookies Policy
We are The Merry Opera Company Limited, trading as Merry Opera. Our company number is 06770652 and we are a non-profit-making registered UK charity, number 1127392. Our address is Vexour Farm, Chiddingstone, Edenbridge, Kent, TN8 7BB, United Kingdom. (“We”, “Our” and “Us”), understand that your privacy is important to you and that you care about how your personal data is used and shared online. The data controller is Merry Opera.
We respect and value the privacy of everyone who visits Our website, www.merryopera.com, www.merryopera.co.uk (“Our Site”), and with whom we correspond via direct reciprocal communications such as (but not limited to) email or telephone conversations and business meetings (“Direct Communications”), and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the term “personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or via Direct Communications. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”) and its UK post Brexit equivalent
2. Information About Us
Our Site is owned and operated by Us.
3. What Does This Policy Cover?
4. Your Rights
4.1 As a data subject, you have the following rights under the GDPR, which this Policy and Our
use of personal data have been designed to uphold:
4.1.1 the right to be informed about Our collection and use of personal data;
4.1.2 the right of access to the personal data We hold about you (see clause 11);
4.1.3 the right to rectification if any personal data We hold about you is inaccurate or incomplete
(please contact Us using the details in clause 12);
4.1.4 the right to be forgotten (meaning the right to ask Us to delete any personal data We hold
about you). We only hold your personal data for a limited time, as explained in clause 6 but
if you would like Us to delete it sooner, please contact Us using the details in clause 12;
4.1.5 the right to restrict (i.e. prevent) the processing of your personal data;
4.1.6 the right to data portability (obtaining a copy of your personal data to re-use with another
service or organisation);
4.1.7 the right to object to Us using your personal data for particular purposes; and
4.1.8 rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of your personal data, please contact Us
using the details provided in clause 12 and We will do Our best to solve the problem for you.
If We are unable to help, you also have the right to lodge a complaint with the relevant supervisory authority.
5. What Data Do We Collect?
5.1 Depending upon your use of Our Site and our Direct Communications, We may collect
some or all of the following personal and non-personal data:
5.1.2 business/company name and other information such as activities and business size;
5.1.3 job title;
5.1.5 contact information such as email addresses and telephone numbers;
5.1.6 demographic information such as post code;
5.1.7 gender, voice type, curriculum vitae details
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of
the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see clause 7 below.
6.2 Our use of your personal data will always have a lawful basis, either because it is necessary
for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails in writing, or subscribing verbally and having it confirmed in writing to you by Us), or because it is in Our legitimate interests (see details of Our Legitimate Interest Assessment in Appendix 1). Specifically, We may use your data for the following purposes:
6.2.1 supplying Our services to you (please note that We require your personal data in order to
enter into a contract with you);
6.2.2 personalising and tailoring Our services for you;
6.2.3 replying to emails from you;
6.2.4 supplying you with emails that you have opted into (you may unsubscribe or opt-out at any
6.3 You have the right to withdraw your consent to Us using your personal data at any time,
and to request that We delete it.
6.4 We do not keep your personal data for any longer than is necessary in light of the reason(s)
for which it was first collected. Data will therefore be retained for the period that you remain as one of our members.
7. How and Where Do We Store Your Data?
7.1 We only keep your personal data for as long as We need to in order to use it as described
above in clause 6, and/or for as long as We have your permission to keep it.
7.2 We may also use outsourced services in the United Kingdom, the European Union and
countries outside the European Union from time to time in other aspects of our business, for
example in the circumstances set out in clause 8 below.
7.3 As such, data obtained within the UK or any other country could be processed outside the
European Economic Area.
7.4 For example, some of the software we use, or our website uses, may have been developed
in the United States of America or elsewhere.
7.5 We use the following safeguards with respect to data transferred outside the European
7.5.1 the data protection clauses in our contracts with data processors include transfer clauses
written by or approved by a supervisory authority in the European Union, specifically that in the UK; and
7.5.2 we comply with a code of conduct approved by a supervisory authority in the European
Union, specifically that in the UK.
8. Do We Share Your Data?
8.1 In certain circumstances, We may be legally required to share certain data held by Us, which
may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority.
8.2 We will never share, sell, rent or trade your personal information to any third parties for
marketing purposes without your prior consent.
We may share your details with:
Service providers who work on Our behalf to carry out any contract We enter into with them or you, for example printers and mailing houses, marketing agencies, database services, website hosting or email delivery services
Other organisations such as competition organisers if you choose to take part in activities that require administration by third parties and you choose to opt in for contact from those organisations
Third party data services, for example Audience Agency, who help us to segment and understand our audience by providing additional information so that We can send the most relevant and targeted communications possible
We are not responsible for the privacy notices and practices of other websites even if accessed using links from Our Site, and We recommend you check the policy of each website you visit and contact its owner or Data Protection Manager if you have any concerns or questions.
Despite all Our precautions, no data transmission over the internet is 100% secure. We
cannot guarantee the security of any information which you disclose to Us.
9. How Can You Control Your Data?
When you submit personal data via Our Site or Direct Communications, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
10. Your Right to Withhold Information
You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at email@example.com, or using the contact details below in clause 12.
12. Contacting Us
APPENDIX 1: Legitimate Interest Assessment (LIA)
We may collect personal data because it is in our legitimate interests. We conduct a Legitimate Interest Assessment (LIA) for all personal data We hold, and conduct regular audits of such Assessments.
The following criteria and guidelines are used to assess whether collection of personal data is in our legitimate interests. These have been formulated in accordance with guidelines from the Information Commissioner's Office.
(1) Are We using your data in ways that you would reasonably expect and that have a minimal privacy impact?
(2) Have We had a two-way dialogue with you (for example via email, telephone or in a business meeting) about Our products or services, and during this dialogue have you expressed an interest in our products or services?
(3) And is it therefore reasonable for Us to believe that you could be interested in Our services in the future?
In such circumstances, We may get in contact in a proportionate and non-intrusive way to see if you have need of Our products or services.
In every such communication, it will be clear how you can request not to receive such communications in the future. As well as sending out individual emails, We use Mailchimp to send out a newsletter about Us and Our forthcoming tours.