RSVP Online Privacy Notice


BACKGROUND:


RSVP Online Ltd (RSVP Online) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of RSVP Online users and subscribers. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.


  1. About Us

RSVP Online is a platform used by film and media companies to:

  • properly manage and maintain their mailing lists;

  • send emails promoting related events such as film screenings;

  • send invitations to events and manage resulting RSVPs and issue tickets; and

  • manage guest lists for events.

RSVP Online is also used by journalists and media contacts to connect with film and other media companies and request to join their mailing lists in order to receive promotional emails and invitations to related events.

RSVP Online is a limited company registered in England under company number 13142556.

Registered address: 8 Victoria Business Park, Short Street, Southend-On-Sea, Essex, United Kingdom, SS2 5BY.

Our Data Protection Lead: Lee-Anne Pawley.

Email address: lee-anne@rsvp-online.com

Telephone number: 08432 893645.


  1. What Does This Notice Cover?

This Privacy Notice explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.


  1. What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.


  1. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

        1. The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

        2. The right to access the personal data we hold about you. Part 10 will tell you how to do this.

        3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

        4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.

        5. The right to restrict (i.e. prevent) the processing of your personal data.

        6. The right to object to us using your personal data for a particular purpose or purposes.

        7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

        8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

        9. Rights relating to automated decision-making and profiling - we do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.


  1. What Personal Data Do You Collect and How?

We may collect and hold some or all of the following personal and non-personal data:

  • Identifiers i.e., your name and date of birth

  • Contact information including your email address and telephone number.

  • Employment information including current and past roles/job titles and employers.

  • Profile information including old and active mailing list subscriptions, records of consent given and revoked, records of event invitations and RSVPs etc.

  • Social media accounts including platform handles and images.

We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.

You provide all data to us directly or via our customer whose mailing list you are subscribed to. If you do not supply basic identity and contact information, we may not be able to provide our basic products and services to you.

You control how much additional information you share on your profile and whom it is shared with; this includes information about your employment, or social media channels. You will still be able to use the RSVP Online service, but it will be harder for film and media companies to assess your suitability for inclusion on their mailing lists and at their events.

  1. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we process your personal data, and our lawful bases for doing so:


Processing

What Data We Use

Our Lawful Basis

Administering our business

Basic personal identifiers

Contact information

Performance of a contract

Guest Request (requesting a ticket without registering an account)

Personal Identifiers, Contact Information

Legitimate Interest

Providing you with an RSVP Online Profile

Basic personal identifiers

Contact information

Employment information

Social media accounts

Performance of a contract (you control how much data you share via your RSVP Online profile)

Supplying our products and services to you including

Basic personal identifiers

Contact information.

Performance of a contract

Managing payments for our products and services.

Payment information.

Performance of a contract

Sending promotional emails (you may revoke consent at any time via your account or by contacting us directly).

Basic personal identifiers

Contact information.

Consent

Operating and maintaining an unsubscribe/do not contact list

Basic personal identifiers

Contact information

Legal obligation

Operating our RSVP Online Blacklist which prevents users and subscribers who have previously breached our guidelines from re-subscribing

Basic personal identifiers

Contact information

Performance of a contract


We will only send promotional and marketing emails when we have your consent to do so. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you are able to revoke your consent at any time.

We will always obtain your opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to revoke consent at any time. This is applicable when you subscribe to third party mailing lists using the RSVP Online platform.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.


  1. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):


Records

How Long We Keep It

User profile containing identifiers, contact, employment, profile and social media information.

18 months after the user account closed.

Ticket Request Record

Registered Users - 18 months after close of account. Non Registered Users - 6 months after the event.

Records of consent given and revoked

Indefinitely

Guest user forms/Guest lists

28 days after event

Unsubscribe records

Indefinitely

Blacklist entry

Indefinitely or until the ‘ban’ is lifted in accordance with our Terms.




  1. How and Where Do You Process or Transfer My Personal Data?

We process most of your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We process and transfer some of your personal data in countries outside of the UK. Where possible this is within the European Economic Area (the “EEA”) or to countries that are deemed to provide an adequate level of protection for personal data. For further information about adequacy decisions and adequacy regulations, please refer to the Information Commissioner’s Office .

At times we process and transfer your personal data to “third countries”. When we do, we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.

Please contact us using the details below in Part 11 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality; and

  • adopting procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.


  1. Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:

  • Sharing with carefully selected suppliers, sub-contractors and advisors who support the operation of our service, or manage connected products. At present this includes:

    • GSuite

    • Digital Ocean

    • MailJet

    • Brevo

    • CYB Support

    • Film Distributors (inc. trading body, the FDA) and relevant PR Agencies as necessary


  • If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

  • In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that it is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.


  1. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email address shown in Part 11.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within one month. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.


  1. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Lee-Anne Pawley):

Email address: lee-anne@rsvp-online.com.

Telephone number: 08432 893645.

Postal Address: 8 Victoria Business Park, Short Street, Southend-On-Sea, Essex, United Kingdom, SS2 5BY.


  1. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available via www.rsvp-online.com/privacy

This Privacy Notice was last updated on 01/07/2022.

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