When we talk about LW Theatres we mean LW Theatres Group Limited, registered number 03987955, of 65 Drury Lane, London, WC2B 5SP (“us”, “we”, “our”). LW Theatres owns and operates the www.lwtheatres.co.uk website and the separate websites (or dedicated webpages) of each of our theatres (Adelphi Theatre, Cambridge Theatre, Her Majesty’s Theatre, The London Palladium, Gillian Lynne Theatre, Theatre Royal and The Other Palace). When you interact with us through our websites (or otherwise, including purchasing tickets directly at our theatres) you may provide to us, or we may collect, certain information from which you are personally identifiable (which is referred to as personal data).
For the purposes of the data protection laws, we are the “data controller”, meaning that we are responsible for deciding how your personal data is used and more importantly, for keeping your data safe and only using it for legitimate purposes.
What this policy explains
NHS Test and Trace and temperature monitoring
What data we collect about you
Why we use your data and our legal grounds for doing so
Who we share your data with
Whether we send your data outside of the EEA
LW Theatres marketing communications and how to opt-out
When and why you might see adverts for LW Theatres online
How we keep your data safe
Third party websites
How long we store your data
Your rights and how to exercise them
Changes to our policy
How to contact us
NHS Test and Trace and temperature monitoring
NHS Test and Trace
To support the efforts of NHS Test and Trace the Department of Health and Social Care (“DHSC”) has asked certain businesses to keep a temporary record of visitors and customers booking tickets to their venues for 21 days and supply such data to the NHS Test and Trace service where requested.
We intend to co-operate fully with the NHS Test and Trace service and will ask each visitor and lead booker to provide certain details when booking tickets to any of our theatres for this purpose. By maintaining these records and sharing them with NHS Test and Trace where requested we can together help to identify people who may have been exposed to Covid-19.
We will collect the minimum amount of personal data required in order to sensibly comply with government guidance, with reference to the point we collect such data (https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace). As we have decided to collect data from visitors to the stage door and the lead booker of tickets to our theatres, we will collect the following:
- The name of the visitor or lead booker;
- A contact phone number for the visitor or lead booker;
- The date of attendance at our theatre; and
- The performance start time of the event being attended so we can calculate the time spent at our theatre (or where a visitor is not attending the theatre 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 individual who provides it. We will not verify any individual’s identity for NHS Test and Trace purposes.
Note – we will not ask individuals to provide us with any health information (special category data under the GDPR) at any time. We will however remind individuals of our entry conditions to the theatre (which may involve a self-assessment by the individual of their health, along with other factors) and highlight that if the individual is feeling unwell, displaying any symptoms of Covid-19 or believe they could be refused entry to the theatre on the basis of their own self-assessment of their individual circumstances then they should not enter the theatre.
Use of data
The data collected above for the NHS Test and Trace service will only be used for contract tracing and not for any other purpose.
We will pass the data collected to the NHS Test and Trace service, which is operated by the DHSC, where requested. We will not supply such data to any other third party.
We will keep the data collected for a period of 21 days, in line with the government’s guidance on this issue (https://www.gov.uk/guidance/maintaining-records-of-staff-customers-and-visitors-to-support-nhs-test-and-trace#how-records-should-be-maintained). Once this retention period has ended we will securely delete the data.
Notwithstanding the above, the data collected for the NHS Test and Trace service may also cover information that we would usually collect and hold onto as part of our ordinary dealings with you. Where this is the case, this information only will continue to be held after 21 days and we will use it as we usually would, unless and until you tell us not to.
We are required to demonstrate that we have a GDPR-specified lawful basis for processing this personal data collected for NHS Test and Trace. We have identified that this personal data is processed under the ‘legitimate interests’ basis, where the legitimate interest is facilitating contact tracing in respect of Covid-19 and the processing is necessary to achieve such interest given that the government has recommended these measures and we have procedures in place to protect the individual data providers’ interests, rights and freedoms.
If you require any further information regarding our collection of personal data in connection with the NHS Test and Trace service then please email us at email@example.com.
Please note that whilst undergoing a temperature check via our thermal imaging equipment may be a condition of entry at our theatres we will not make a record of the result of any temperature check or retain any associated personal data.
Information regarding temperate checks will be used by our staff to make an immediate decision regarding entry to a theatre. There is no automatic temperature screening or processing by automated means.
For the above reasons we do not consider this to constitute processing of personal data and it follows that this activity is not regulated by the GDPR.
What data do we collect about you?
We have set out below the different types of personal data that you provide directly to us, or which we collect from you when we interact. We also wanted to let you know why we use this data and the different legal grounds which allow us to do so. You don’t have to give us any of this data but if you don’t, you may not be able to buy tickets and you are unlikely to receive our optimal overall customer experience. But that is your choice – and we respect that.
You may provide us with the following types of personal data when you directly interact with us (through our websites, in person at our theatres or otherwise):
Contact – first name, surname, gender, DOB, account log-in information, country of residence, email address, telephone numbers and address
Financial –billing address, purchase information, payment history
Profile – your preferences for marketing, other website preferences, your contact history and feedback on your LW Theatres experiences through reviews surveys
Social – if you choose to use the free wifi service in one of our venues we will open an LW Theatresaccount for you. Your Facebook account details may be passed through to us if you choose this way of signing in. We will use your contact information used for the relevant account to help populate your registration page and create your account, as well as using your page likes to find shows that are relevant for you.
We may also collect the following types of personal data from you when you use our websites (using Cookies or other tracking technologies):
Technical – browser type, device information, IP address, hardware type, network and software identifiers, operating system and system configuration
Usage – information about how you use our websites, including time spent on page, click-throughs, download errors, browsing patterns
Why do we use your data and what are our legal grounds?
The table below sets out how we use your personal data and our lawful basis for doing so. In addition to these purposes, please note that we also anonymise and aggregate personal data (so that it does not personally identify you) and use it for testing our internal systems, carrying out research and general customer data analysis. Because this is not personally identifiable, we can use this for any purposes.
|Reasons why we use the data||WHAT DATA||LEGAL GROUND FOR USING THE DATA|
|Register you as a LW Theatres customer and enable you to log-in once you have registered||Contact, Profile, Social||Perform our contract with you Necessary for our legitimate interests (to make your purchase experience more user friendly)|
|To enable you to put tickets and other products in your basket and save for later||Contact, Social, Technical, Usage||Same as above|
|Process payments for tickets and other products which you make through our websites and to action refunds||Contact, Financial||Perform our contract with you|
|Deliver your tickets and other products||Contact||Same as above|
|Send you service messages by email, including ticket receipts, show information and updates on your order of other products||Contact||Same as above|
|For internal administration and record keeping purposes||All||Perform our contract with you. Comply with our legal obligations. Necessary for our legitimate interests (to effectively operate our business and perform our services)|
|Providing customer support, including answering your questions which may involve contacting you by post, e-mail or phone||All||Performance of a contract with you. Necessary for our legitimate interests (to ensure our customers are informed and satisfied with our services)|
|To understand who is buying our tickets and other products||Contact||Necessary for our legitimate interests (to develop our business and understand our customer base to inform our marketing strategy)|
|Get in touch with you about relevant LW Theatres shows and products||Contact, Profile||We only do this if we have your consent|
|Improve and personalise your user experience by delivering more relevant LW Theatres content and advertising whilst you browse and to remember your preferences||Contact, Profile, Social Technical, Usage||Necessary for our legitimate interests (to develop our business, improve our user experience and inform our marketing strategy)|
|Administer our websites, including website trouble shooting, testing and analysis and to enable you to participate in interactive features of our websites||All||Performance of a contract with you. Necessary for our legitimate interests (to ensure that our websites are fully functional and operating in the most effective way for you)|
|Enable you to participate in a competition or prize draw||Contact||Perform our contract with you|
|Give you the opportunity to provide feedback to LW Theatres through reviews and surveys||Contact, Profile, Technical, Usage||Necessary for our legitimate interests (to develop our business, promote new products and services, obtain feedback from customers to improve our services)|
|Verify your identity and detect fraud and security issues||All||Necessary for our legitimate interests (to prevent and detect fraud, security incidents and criminal activity)|
Sharing your data
Importantly, we do not pass your personal data to any third parties for the purpose of third party marketing. If in the future we want to do this, we will only do so if you have consented.
However, we do need to share your data with the following third parties as an essential part of being able to provide our services to you (in accordance with the purposes set out above). In each case, we will only ever share the minimum amount of information required, and ensure that the relevant third parties are subject to suitable obligations in respect of confidentiality and security:
– Companies which are within the same corporate group as LW Theatres, who are responsible for managing different aspects of our service delivery
– Payment service providers and our delivery companies
– Our professional service providers, such as marketing agencies, advertising partners and website hosts and our professional advisors
– Credit reference agencies, law enforcement and fraud prevention agencies, so we can help tackle fraud
– Companies approved by you, such as social media sites (if you choose to link your accounts to us)
In addition to the above, we may also need to share your personal data with third parties if we are legally obliged to.
Do we send your data outside of the EEA?
The European Economic Area or “EEA” is seen as having good standards when it comes to data privacy. As such, we do not transfer your data outside of this area. If a situation arises where this is necessary, we will make sure that your data is still treated fairly and lawfully in all respects (including making sure we have a legal ground for the transfer and putting in place all necessary safeguards for such arrangement where the third party is not based in a country which is deemed to have “adequate” data protection laws).
Where applicable, you will have the right to see a copy of any safeguards we put in place for international transfers of your data. Just Contact Us if you would like to find out more.
Marketing messages and opt-ing out
If you have said we can, we’ll send you marketing messages by email and/or post to keep you aware of what we’re up to and tell you about future shows we think will be relevant to you or other services and promotions. If you change your mind, you can opt-out of receiving marketing at any time either by Contacting Us, or by using the opt-out function detailed in the communication. Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Please note, it might take a few days for all our systems to be updated, so you might get messages from us while we process your request.
We do not currently pass your data onto any third parties for marketing purposes, unless you have explicitly asked us to do so. However, if we ever wish to do so in the future we will always get your consent. You can then opt-out from any third party marketing at anytime following the same process as above.
Seeing adverts for LW Theatres elsewhere on the web
If you have given the appropriate consent, LW Theatres targets banners and ads to you when you have left our websites and are on other websites and apps. We do this using a variety of digital marketing networks and ad exchanges, and we use a range of advertising technologies like pixels, ad tags, and cookies, as well as specific services offered by some sites and social networks, such as Facebook’s Custom Audience service.
The banners and ads you see will be based on information we hold about you, or your previous use of LW Theatres (for example, tickets you forgot to buy last time you were on the relevant website, or from reading a synopsis of a new show) or simply from LW Theatres banners or ads you have previously clicked on.
For more information, please read our Cookies Policy below.
How we keep your data secure?
We implement industry standard security processes to ensure your data is kept safe and secure and to prevent unauthorised access or use or loss of your data. We also make sure that when we are required to share your data with third parties, they are subject to suitable confidentiality and security standards.
Despite these measures, the transmission of data via the internet is not completely secure. As such, we cannot guarantee that information transmitted to us via the internet will be completely secure and any transmission is at your own risk.
Links to third party websites
How long do we store your data?
We will store your data for as long as you have an active LW Theatres account*, or as long as is needed to be able to provide the services to you and/or where you are still happy to hear from us about our latest news, products and services.
After this, we may still need to keep hold of your data if there is a legal reason for doing so (such as for tax or other financial reasons (such as being able to deal with chargebacks), where we need to resolve any disputes with you, or where we need to enforce our terms and conditions).In such circumstances, we will only retain the amount of data strictly necessary for these reasons and otherwise, will remove your data from our systems.
*If you’ve not used your account for more than three years, it will be flagged as inactive and we’ll contact you to ask whether you want to keep it open. Unless you reply to say ‘yes’, we’ll close the account and delete or anonymise the personal data associated with it (unless the above applies).
You have various rights under GDPR which entitle you, in certain situations, to:
– ask us for a copy of the personal data we hold about you;
– correct or update your personal data, which you can do yourself by logging into your account or if you would prefer, please contact us and we can assist;
– request that we delete your personal data;
– object to the handling of your personal data where we are relying on a legitimate interest (as set out in the above table);
– restrict the processing of your personal data;
– request the transfer of your personal data (or some of it) to a third party service provider; or
– where you have provided your consent for something, in certain circumstances, you may withdraw this consent (but note that we may continue to use your personal data if we have legal grounds for doing so).
And how to exercise them….
Please Contact Us if you would like to exercise your rights, which you can do for free. The only time we may be allowed to charge a reasonable fee is where your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. Otherwise, we will always respond within one month (unless there is a legal reason to take longer).
We may also need to ask you to confirm your identity before we proceed with your request if it is not clear who is making the request.
If you are concerned about the way we are handling your personal data you may also contact the ICO (Information Commissioner’s Office). However, where possible, we would really appreciate the opportunity to help with your concern in the first instance.
Changes to this policy
We may change this policy from time to time, to reflect how we are handling your data and will upload these updates onto our websites. If we make significant changes, we will make sure these are notified to you by email or other suitable method so that you are able to review the changes before you continue to use our services.
How to contact us
If you would like to discuss anything in this policy, want to exercise your rights or have any issues with the way we are handling your data, please:
Email us: firstname.lastname@example.org
Write to us at: LW Theatres, 65 Drury Lane, London, WC2B 5SP
The lwtheatres.co.uk website (operated by LW Theatres Group Limited, registered number 03987955, of 65 Drury Lane, London, WC2B 5SP – “LW Theatres”, “we”, “us” or “our”) uses tracking technologies including cookies. These distinguish you from other users of our website and may: 1) be fundamental to the running of our website; 2) help the website to perform effectively; 3) allow us to deliver a more personalised browsing experience; 4) keep you interested in LW Theatres, even after you have left our website; 5) enable us to understand our customers’ browsing behaviour; and/or 6) allow us to improve our website.
What are cookies and tracking technologies?
These enable us and trusted third parties (details provided below) to store information on your device/browser to enable us (or them) to identify you and monitor certain activities, for the purposes set out in this policy.
These technologies may be: 1) “session cookies” – expiring at the end of your browser session (allowing us to link your activities during that session); 2) “persistent cookies” – staying on your browser/device after you have finished browsing, enabling us to remember your preferences for the next time you visit. These will either expire after the particular period set by that cookie or will need to be deleted manually; 3) be set by us; or 4) be set by third parties.
Importantly, we will not use any cookies or similar technologies (or permit any third parties to place these on our website) which are not strictly necessary for the operation of the website, without first getting your consent. You can change your mind at anytime about any cookies or similar technologies – please read the “How to block these cookies/tracking technologies” section below to understand how.
Please note that third parties who place cookies on our website will have their own terms and conditions and privacy policies, so we recommend you read these carefully.
What cookies/tracking technologies do we use?
|Strictly necessary||These are essential for the operation of our website. They include, for example, cookies that enable you to log into your account and use our shopping basket when you wish to purchase tickets.|
|Analytical/performance||These allow us to recognise and count the number of website visitors and to understand browsing patterns (e.g. how long you spend on pages, whether you experience download or other errors, what pages you are interested in etc). This helps us to operate our website more effectively, understand our customers better, to enable us to continually improve our services.|
|Functionality||These recognise you when you return to our website. This enables us to personalise your browsing experience by tailoring the content you see, greeting you personally without you needing to input your details each time and to remember your preferences.|
|Targeting||These record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.|
|Re-targeting||These record the same types of information as above but display LW Theatres advertising once you have left the LW Theatres website.|
Third Party Cookies
a web analytics service
provided by Google, Inc.
|Analytical/performance||Google Analytics sets a cookie in order to evaluate your use of our website and compile reports for us
on your activity.
Google stores the information collected by the cookie on servers in the United States.Google may also transfer this information to third parties where required to do so by law,
or where such third parties process the information on Google’s behalf.Google will not associate your IP address with any other data held by Google.
Please read https://policies.google.com/privacy?hl=en to understand how to reject this cookietypekit.netAnalytical/performanceUsed on the site to produce anonymous statistical data on how the visitor used the website.Yahoo.com, bidswitch.net, tapad.com, adsrvr.orgAnalytical/performanceUsed to engage visitors that are likely to convert to customers based on the visitor’s on line behaviour across websites.facebook.comFunctionalityUsed by Facebook to register impressions on pages with the Facebook log in button.addthis.comFunctionality
AddThis is a third party service that allows you to share content from our site via social media.
These cookies are required to allows the service to operate.
Google AdWords, an advertising service provided by Google, Inc, doubleclick.net, an advertising platform provided by Google, Inc, facebook.com, krxd.net, acxiomapac.com, adnxs.com, spotxchange.com, rqtrk.eu, rubiconproject.com, rfihub.com, rlcdn.com, pubmatic.com, eyeota.net, casalemedia.com, demdex.net, media.net, ru4.com, everesttech.net, openx.net, serving-sys.com, bluekai.com, taboola.com, mid.rkdms.com, soma.smaato.net, addthis.com, gssprt.jp, w55c.net, openx.netTargetingUsed by advertising platforms to engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites. These advertisers may aggregate data from other third party sources to make advertising more relevant to you. Where possible, this data is anonymised, but based on your agreements with specific third parties, personal data may be enhanced.Google AdWords, an advertising service provided by Google, Inc, doubleclick.net, an advertising platform provided by Google, Inc, facebook.com, krxd.net, acxiomapac.com, adnxs.com, spotxchange.com, rqtrk.eu, rubiconproject.com, rfihub.com, rlcdn.com, pubmatic.com, eyeota.net, casalemedia.com, demdex.net, media.net, ru4.com, everesttech.net, openx.net, servingsys.com, bluekai.com, taboola.com, mid.rkdms.com, soma.smaato.net, addthis.com, gssprt.jp, w55c.net, openx.netRetargetingUsed by advertising platforms to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites. These advertisers may aggregate data from other third party sources to make advertising more relevant to you.
Where possible, this data is anonymised, but based on your agreements with specific third parties, personal data may be enhanced.
How to block these cookies/tracking technologies
You can manage your settings and block cookies/tracking technologies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our website.
In addition to the above, there are particular provisions that govern your data in connection with the presentation of Disney’s Frozen at the Theatre Royal, Drury Lane which are as follows:
The Walt Disney Company Limited (“Disney”) is providing certain ticketing sales, booking and guest services to us and, along with its sub-processor Sutherland Global Services, Inc., will process Contact and Financial personal data on our behalf which will allow us to perform our contract with you and is necessary for our legitimate interests (to effectively operate our business and perform our services).
Close will text you shortly after you book your tickets to Frozen inviting you to download their app and may follow up with a second reminder text message before you are scheduled to attend Frozen if you have not signed up to the Close platform.
Close will delete your relevant opted-in Contact data provided by us with your consent on the earlier of: (i) you signing up to the Close platform, or (ii) the date you are scheduled to attend Frozen. For the avoidance of doubt, Close will not hold the opted-in Contact data transferred by us with your consent following the date you are scheduled to attend Frozen. This will not affect any data you choose to send Close directly, which is governed separately from the provisions set out herein.
Finally, please note that Close may use sub-processors, including: TransIP, Commify, Kovoks B.V. and Liberty Global.
More details on the Close app can be found here: https://www.thecloseapp.com.
Last Updated – 17 July 2020
The ‘NHS Test & Trace and temperature monitoring’ section was added on 17 July 2020