Privacy Policy

OUR PRIVACY COMMITMENT TO YOU

1. WHO WE ARE AND WHAT WE DO

“ATG” and “ATG Entertainment” (and “we”, “our”, “ours” and “us”) refers to ATG Entertainment Limited, a leading venue owner, producer and ticketing operator in the arts and entertainment industry, registered in England and Wales with registration number 2671052 and whose registered office is at Alexander House, Church Path, Woking, Surrey GU21 6EJ.

2. COVID-19 ADDITIONAL INFORMATION (NHS TEST AND TRACE/TEST AND PROTECT, NON-INVASIVE COVID-19 STATUS CERTIFICATION CHECKS)

The UK is currently experiencing a public health emergency as a result of the coronavirus (COVID-19) pandemic. We are taking a range of additional measures to keep our team members, local community and guests safe, including following any government requirements and/or guidance as necessary. This section of our privacy notice explains how we will use your personal information in order to support these efforts.

NHS Test and Trace/Test and Protect

To support the efforts of NHS Test and Trace (for England) and Test and Protect (for Scotland), the Department of Health and Social Care (“DHSC”) and NHS Scotland have asked us to keep a temporary record of visitors to our venues for 21 days and supply such data to the NHS Test and Trace service (in relation to England) and NHS Test and Protect (in relation to Scotland) where requested by them.

The provision of such personal information is voluntary. However, we would encourage all visitors to share their details with us in order to support these NHS schemes on the basis that such information will only be used where necessary to help stop the spread of Covid-19.

Our processing of such personal information is on the basis of the legitimate interest of facilitating contact tracing in respect of Covid-19. We consider that this processing is necessary to help stop the spread of Covid-19 and keep our staff and visitors to our venues safe. Note also that the government has recommended these measures be put in place. Please note that we have procedures in place designed to protect the personal data you provide to us for these purposes (see below).

Where you purchase a ticket from us for a show or event which is taking place at a non ATG venue which is operated by a third party, we may also be asked to share your personal information with the venue or directly to the relevant NHS scheme if requested. Where the data is shared with the venue, the venue will at that point become responsible for your data for the period that it holds it as an independent data controller. In most cases the venue will be clear from your ticket and booking information but if in any case this is not clear please do not hesitate to contact us. For more information on how our venue partners handle your information you should consult their privacy policy.

Information collected

When you book a ticket for an event (either directly or with a 3^rd party agent), we will collect the following data about the lead booker (as per normal requirements):

• The name of the booker;
• A contact phone number for the lead booker (or address and/or email address where a phone number is not available);
• The date of attendance at the venue; and
• The performance start time of the event being attended by the visitor so we can calculate the time spent at the venue (or where the visitor is not attending the venue for a specific event we will ask for the visitor’s arrival time and estimated time of departure, with the option to confirm the actual time of departure later).

The accuracy of the information provided will be the responsibility of the visitor who provides it. We will not verify any visitor’s identity for NHS test and trace purposes. We will not collect any additional data for these purposes.

How we use your data

The data collected above for the applicable NHS test and trace service will only be used for contact tracing and not for any other purpose unless we ordinarily collect such data for other purposes and as set out in this privacy policy. We will pass the data collected to the relevant NHS test and trace scheme or the venue to share with the appropriate NHS scheme, where requested by them.

We will keep the data collected for a period of 21 days, in line with the government’s guidance. Once this retention period has ended we will securely delete the data (unless we already collect and keep such data for other purposes, in which case it will be deleted in line with our retention policy).

For more information on how NHS Test and Trace works please visit here: https://www.gov.uk/guidance/nhs-test-and-trace-how-it-works

For more information on how NHS Test and Protect works please visit here: https://www.nhsinform.scot/campaigns/test-and-protect

For more information on how NHS Test, Trace, Protect works please visit here: https://gov.wales/test-trace-protect-coronavirus

NHS Scotland’s privacy notice on NHS Test and Protect can be found here: https://www.informationgovernance.scot.nhs.uk/covid-19-privacy-statement/

If you do not wish us to share your personal information with NHS Test and Trace or NHS Test and Protect, please contact us. See the Contact Us section below on how to do this.

Non-invasive Covid-19 Status Certification (“CSC”) checks

As part of a range of measures designed to combat the spread of Covid-19 and to protect our staff, customers and local community, venues may carry out CSC checks.

Compliance with our CSC checks may be a pre-condition to our venues.

How we will use your personal data:

Your CSC and proof of identification (if necessary) will be used by our staff at our venues to make an immediate decision regarding whether you should be allowed entry to such venue. Your CSC information constitutes “special category” personal data under the GDPR as it relates to your health. In providing us with your CSC evidence, you will be deemed to consent to us processing your health data in order to assess whether you should be allowed to enter our venues. If you do not consent to us processing your personal data in this manner, you should not attend our venues.

It is also in our legitimate interests to process your CSC and proof of identification (if necessary) as set out above, as this will enable us to re-open our theatres whilst also helping to protect the health and safety of our customers and staff. We also believe that carrying out these checks is necessary for reasons of public interest in the area of public health. Please note that there is no processing of your personal data in this regard by automated means

When processing your personal data in the way described in this section on non-invasive CSC checks, we owe you a duty of confidentiality and will treat all information disclosed to us as part of the CSC checks as confidential.

Whilst undergoing a CSC and identification check may be a condition of entry at the event/venue, we will not retain a record of the result of any CSC or identification check. If you receive a positive Covid-19 test result which means that you are no longer able to attend a certain event, you/your party will be entitled to a credit voucher, allowing you to rebook and see the show on an alternative date. In such a case, we will retain a record that you/your party are entitled to a credit voucher but we will not retain a record of your positive test result.

Where the event/venue is operated by a 3rd party, please refer to the relevant venue/event partner’s privacy policy in relation to how they use your data in relation to non-invasive CSC checks.

3. HOW WE USE YOUR PERSONAL INFORMATION

What information will you collect from me?

When you use our website(s) or other services, we may collect and use your information in several different ways. The main reasons are:

• To perform the requested service or contract with you;
• To comply with our legal obligations
• For our legitimate business interests, which may include but not be limited to, provide information on our shows and services and analyse the use of our websites and services to continually improve your customer experience and our business: and
• You have provided consent for us to collect and process your personal information

Please note that if you choose not to share your personal information with us, or refuse certain contact permissions, we may not be able to provide you with some services that you have asked for.

How and when we collect your personal information

Generally, we collect your information when you decide to interact with us. This could include purchasing online, over the phone, in person at a ticketing booth or self service kiosk, when you sign up to receive emails from us. We also look at how our website(s) is used, so that we can offer the best possible experience.

We collect information in a number of ways, which are listed below:

• When you register or use our website(s);
• When you register to use Wifi services in our venues;
• When you purchase/utilise a product or service on our website(s), at one of our venues, or by phone;
• When you download or install one of our apps;
• When you register for an ATG TheatreCard or for the Access Scheme;
• When you contact us by any means with queries, complaints etc.;
• When you engage with us on social media;
• When you enter any event, prize draws or competitions run by us;
• When completing any surveys that we send to you for research purposes or when we ask you to provide feedback or write a review (although you are under no obligation to complete these);
• When you fill in any forms. For example, if an accident happens in one of our venues, we may collect your personal data to create a report of this incident;
• When you visit our website(s). We may use cookies to help make the experience of using our website(s) better and to personalise the service you receive from us – this means we will remember your previous visits and track the pages on our website(s) that you visit. For more information please see our Cookie Policy;
• When you visit our venues, these usually have CCTV systems operated for the security of both customers and partners. These systems may record your image during your visit.

We may also receive information about you from:

• Independent organisations, for example other organisations that we have worked with. These independent organisations will only do so when there is a lawful basis to do so. You should check their privacy policies when you provide your information to them, to understand fully how they will process and safeguard your data;
• Publicly-available sources (such as Land Registry) when you have given your consent to share information or where the information is made public as a matter of law.

What Personal information we may collect

We will collect personal information that you submit to us when you make use of our website(s) or services and/or you contact us. This information may include, but not be limited to:-

• Your name and contact details
• Your date of Birth
• Information about your gender
• Your payment information
• Your contact history with us
• Purchase history
• CCTV Images
• Engagement details including your marketing preferences and feedback

How we use the Personal information that you provide us with

• Register you as a user of our website(s) or other services
• To take and fulfil your order for tickets or administer other services such as food and beverage orders, the ATG TheatreCard, the Access Scheme or any of our prize draws or competitions which you enter, based on your consent given at the time of entering
• To contact you about any cancellations, amendments or additional information in respect of your ticket order, or any other services that we provide to you
• Tailoring your experience at an event or in our venues
• To take payments and provide refunds, where necessary
• Provide customer service and support
• To respond to your queries, refund requests and complaints
• Sending you information by email, SMS, push notification or post, about our products and services
• Showing you ATG adverts as your browse the web
• To provide wifi services that you have registered for
• Fraud prevention and detection
• Train our staff
• To monitor customer experience and our overall own performance
• To contact you in order to invite you to review any of our services/products and/or performances in order for us to collect feedback, improve our services/products, and to use such reviews in our promotional material and media for our advertising and promotional purposes.
• When you visit our venues, these usually have CCTV systems operated for the security of both customers and partners. These systems may record your image during your visit.

Please note that if we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.

What about sensitive personal information?

In the course of providing our goods or services to you, we may collect information that could reveal your religious beliefs or information about your health. Information like this is considered “sensitive personal information” under data protection laws. We only collect this information where you have given your explicit consent, it is necessary, or you have deliberately made it public.

Examples of when we may collect this information could be in the following circumstances:

• If you request special assistance when visiting one of our venues or purchasing tickets, this could reveal information about your health (for example if you ask for a signed performance or require a wheelchair accessible seat).
• If you inform us about specific dietary requirements you may have, this could potentially indicate that you have specific religious beliefs.

When you provide us with any sensitive personal information, you explicitly agree that we may collect it and use it in accordance with this Privacy Policy.

If you do not allow us to process any of your sensitive personal information, this may mean that we are unable to provide all or part of the services that you have requested from us. Please be aware that in such circumstances, you may not be entitled to cancel or obtain a refund of any price that you have already paid.

Technical Information we collect from you

We automatically collect certain limited information about your device and your visits to our websites which may be considered personal information. This information may include the type of data set out below.

• Device data -the type of device or platform that you use to access our wifi services, website(s), such as a computer or mobile device.
• Location data - Your use of our wifi service, websites and services may generate geographical data, e.g. the location or time zone of a device, or an IP address which we may collect.
• Log data about your visit- Information about your unique visit to our website, such as URLs, your internet service providers, the number and timing of clicks to and from our website(s), which events you view, page response times, download errors, length of visit to our website pages, page interaction data (e.g. scrolling, clicks and mouse-overs), email engagement rates and activities and methods to browse away from the page.

How we use this Technical Information

• To administer our websites and for our own troubleshooting, analysis, testing, research and statistical purposes
• To improve and optimise our websites and the way content is presented
• Protect our websites and your online account
• To allow you to use interactive features of our websites
• Postcode data is collected and stored to improve our marketing communications to you
• To measure the effectiveness of advertising, and deliver relevant advertising which matches user interests and preferences
• To administer our wifi service

Information we receive from other sources

Certain third parties may provide us with personal information about you. In each case, it is the third party’s responsibility to ensure that is has obtained your consent to share your personal information with us. Where possible, we will ask a third party to confirm that it has the right to pass this information to us.

Third party services

You may give us permission to access your personal information in other third-party services, e.g. you may link your account to Facebook or Instagram, which allows us to access content on these platforms.

How we use third party services data

• To improve and optimise our websites and the way content is presented
• To understand more about you

ATG group companies

The companies within the ATG Entertainment work closely to deliver services to you.

How we use our Group data

• To deliver products and services to you
• To administer our websites and for our own troubleshooting, analysis, testing, research and statistical purposes
• To improve and optimise our websites and the way content is presented

Our ticketing agents

We sometimes appoint third party ticketing agents to promote and sell our products on our behalf. Where you have purchased one of our products from an agent it will be necessary for the agent to pass your details on to us so that we can fulfil your order. To contact you about any cancellations, amendments or additional information in respect of your ticket order

Collation of Personal Information

We may collate different categories of information that we collect about you. Where this is the case, and where such collated data amounts to personal information, we will process this data in accordance with this Privacy Policy.

4. SHARING YOUR INFORMATION

We will never sell, exchange or otherwise distribute your personal information to companies outside of our group for their own marketing activities without your consent except to the extent required by applicable laws and regulations, or as set out in this Privacy Policy.

However, we share your data with other companies as an essential part of being able to provide our services to you:

• The venue and event partner(s) in respect of any ticket booking you have made so that they can run the event and for other reasons described in their privacy policies. The name of the venue and/or event partner(s) will usually be stated when you purchase your tickets or it will be provided on your tickets. However, if this is not the case please contact us. For more information on how the venue and/or event partner(s) handle your personal information please consult their privacy policy;
• Our business partners, suppliers, agents and sub-contractors where necessary to fulfil data processing activities for the purposes listed in this policy on our behalf, for example third parties who provide services to us (e.g. payment processors, IT and back office systems, delivery companies, customer relationship management activities) or on our behalf (e.g. our ticketing partners); or
• Analytics and search engine providers that assist us in the improvement of our websites and the services we provide.

Exceptional circumstances

We may also disclose your personal information to third parties if:

• We undergo a change of control or any of our business or assets are sold or transferred (in which case we may disclose your personal information to the buyer to enable them to continue providing services to you);
• We are under a duty to disclose or share your information to comply with any legal obligation (for example, a court order, NHS Test and Trace/Test and Protect); or
• We need to protect our rights, property, the safety of our website users/customers or to help prevent fraud or crime. This may include exchanging personal information with other companies and organisations for the purposes of fraud protection or with governmental and law enforcement authorities.

Anonymised and pseudonymised data

We may anonymise personal information so that you can no longer be identified from such information. We may also pseudonymise your personal information. This allows us to recognise where multiple behaviours are linked, without seeing any personally identifiable data.

5. YOUR INFORMATION AND DIRECT MARKETING

Where you have consented or where we have a legitimate interest, we will use your personal information to contact you via email, SMS, push notification, telephone or post (depending on any preferences notified to us) with relevant information about ATG Entertainment, our websites, our products, services, offers and events. Where you have asked to receive information about our corporate partners or sponsors, your personal information will be used by us to send this information to you.

How to stop electronic marketing messages

You can stop receiving electronic marketing messages (e.g. emails) from us at any time. You can do this:

• By clicking on the ‘unsubscribe’ link in any marketing email; or
• By submitting a request to our Customer Services at help.atgtickets.com or help@novacinema.com

Once you do this, we will update your profile to ensure that you don’t receive any further electronic marketing messages. However, please note that it might take up to 14 days for our systems to be updated, so you might continue to receive messages from us whilst we process your request.

How to stop postal marketing messages

You can stop receiving postal marketing messages from us at any time. You can do this:

• By submitting a request at help.atgtickets.com
• By marking your postal marketing “Return to Sender” Customer Services, ATG Entertainment, 4-5 High Street West, Sunderland, SR1 3EX.

Once you do this, we will update your profile to ensure that you don’t receive any further postal marketing. However, please note that it might up to 30 days (or longer if you use the Return to Sender method) for our systems to be updated, so you might continue to receive marketing from us whilst we process your request.

6. THIRD PARTY LINKS

Our websites and communications with you may provide links to the websites of third parties. Please remember that when you use a link to go from one of our websites to another website, or you request a service from a third party, this Privacy Policy no longer applies.

Your browsing and interaction on any other website, or your dealings with any other third-party service provider, are subject to that website’s or third-party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website that you visit or third-party service provider that you deal with, and to contact them if you have any questions about their respective privacy policies and practices.

This privacy policy applies solely to personal information collected by us through our websites and does not apply to these third-party websites and third-party service providers.

7. KEEPING AND STORING YOUR INFORMATION

Retaining your personal information. We keep your personal information for as long as we require for the purposes for which it was collected (see above). Once the relevant purpose has been satisfied we will securely delete or anonymise your personal information unless we are required to retain a copy of such information under applicable law.

Where we store your personal information. All personal information that you provide is stored on our secure servers or those of our suppliers which may be situated outside of the European Economic Area (“EEA”). Your information may also be processed by staff operating outside the EEA who work for us or for one of our suppliers for the purposes set out in this Privacy Policy. Where we transfer personal information outside of the EEA we will ensure that adequate contractual safeguards are in place (e.g. the European Commission’s standard data protection clauses or “model clauses”), to ensure the security of your personal information is maintained when it is processed by the third party.

8. HOW WE PROTECT YOUR PERSONAL INFORMATION

We are committed to keeping your personal information secure. We take appropriate technical and organisational measures to ensure the security of all personal information we hold (and endeavour to only work with third parties who provide equivalent protections) in accordance with industry best practices (for example, if you provide us with your credit card information, the information is encrypted to ensure its security). However, please note that there are inherent security implications of disclosing personal information online for which we cannot be held responsible.

Account details. You are responsible for keeping the log in details and password in respect of any account you hold with us confidential at all times.

9. WHAT ARE YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

You have rights in relation to the personal information we hold about you, and have the right to:

• A copy of your personal information which we hold about you;
• Request that we correct any personal information that is inaccurate or out of date;
• Withdraw your consent to processing at any time if we have relied on your consent to process your personal information;
• Request in certain circumstances that your personal information is removed from our systems where it is no longer necessary for us to hold your personal information;
• Request in certain circumstances that we transmit your personal information that we hold elsewhere (known as “data portability”);
• Object to us processing your personal information. In this instance, we will stop processing your personal information if we are relying on it for our own or someone else’s legitimate interests, processing it for direct marketing or processing it for research (unless such processing is necessary for the performance of a task carried out in the public interest);
• Restrict the processing of your personal information, if you contest the accuracy of the personal information that we hold about you. This means we must stop any processing activities until we have verified the accuracy of the personal information, or we no longer need your personal information; and
• Contact us directly and be given an explanation about any automated decision-making and profiling that produces a legal (or similarly significant) effect on you.

10. CHANGES TO HOW WE PROTECT YOUR PRIVACY

To ensure that you continue to be aware of how we use your personal information, we will update this privacy policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements.

If we make significant changes this Privacy Policy, we will make that clear the next time you access our website or notify you by some other means of contact such as email, so that you are able to review the changes before you continue to use our website and/or services. However, we encourage you to review this privacy notice periodically to be informed of how ATG uses your personal information

11. HOW WE USE COOKIES ON OUR WEBSITES

We use cookies on our website. For more information on cookies, please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

12. CONTACT US

If you have any questions about this Privacy Policy, or you want to exercise your rights, please get in touch with us by:

• Submit a request online at https://help.atgtickets.com/
• By post: Customer Services, ATG Entertainment, 4-5 High Street West, Sunderland, SR1 3EX.

If you have a concern or wish to make a complaint about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (“ICO”). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.