Legitimate Interests
Where we process your personal data based on a legitimate interest, we will only do so where the processing is proportionate and limited to what is necessary for the purpose it was originally collected for. We will also ensure that our legitimate interests do not override your legitimate interests as an individual.
If you have previously attended one of our events, subscribed to one of our services or we have made an assessment of your interests based on your profession or industry, then, in the absence of consent, the legal basis on which we have processed your personal data and communicated with you is legitimate interest. We have a legitimate interest in communicating with you in order to give you information regarding upcoming events or our other services. In balancing our interests against yours, we take into consideration the facts that the amount of your personal data we process is minimal, that it is not sensitive data, that there is a minimal privacy impact and that you can easily opt out or unsubscribe at any time.
8. If you fail to provide your personal data
Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide you with access to our services or Website. In this case, we may not be able to provide you with our services or access to our Website, in which case we will notify you.
9. How long we will keep your personal data
We store your personal data in accordance with applicable law and will not retain your personal data for longer than is necessary unless required to by other legal or regulatory requirements or to enable us to adequately investigate complaints. If you have any questions about the retention of your personal data, please contact us using the details at section 3 of this Privacy Policy.
10. Sharing personal data
10.1 When we will share your personal data
We will only share your personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. We may share your personal data where:
- you have agreed to the sharing of this information:
- during registration for an event;
- during form submission; or
- while attending one of our events, in particular when attending theatres and visiting stands;
- you have agreed to us sharing your name and email address with carefully selected third parties (such as our exhibitors, sponsors and partners) whose products and services may interest you;
- data sharing is required for us to fulfil a contractual obligation we have with you and/or your organisation;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; and/or
- we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, in which case we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors.) In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events.
The above list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.
10.2 Who we will share your personal data with
The third parties that we may need to share your personal data with are as follows:
- exhibitors and sponsors of events that you attend;
- marketing agencies that have booked a stand on behalf of an exhibitor or sponsor of an event that you attend;
- event partners and suppliers: when we run events, we may share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we may share your personal data with such organisations for use in relation to the event;
- third parties (such as our exhibitors, sponsors and partners): who we believe you will benefit from hearing from about their third party products and services (where you have opted in to us sharing your name and email address);
- advertising partners: we may share personal data with third party advertising partners when you use our Website. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities;
- third-party email marketing and CRM specialists: we may share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications;
- third-party organisations that provide applications/functionality, data processing or IT services: we may share personal data with third parties who support us in providing the Website and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We may also share your personal data with third-party service providers to assist us with insight analytics;
- payment providers and banks: We may share personal data with third parties who assist us with the processing of payments;
- auditors, lawyers, accountants and other professional advisers: We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in;
- courts, law enforcement or other government and regulatory agencies and bodies: We may share personal data with courts, law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation; and
- occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
10.3 Sub-processors
In order to provide our services, we may engage third-party service providers (also known as "sub-processors") to process your personal data on our behalf. These sub-processors may include, but are not limited to, companies providing IT services, marketing services, payment processing, data analysis, event management, and customer support.
We may change or add sub-processors from time to time as part of our business operations. We will ensure that any sub-processor engaged by us is bound by data protection obligations consistent with our own and will take appropriate measures to protect your personal data.
A current list of our sub-processors, which is subject to change, can be made available upon request by contacting us at dataprotection@closerstillmedia.com. If any sub-processor is located outside of the United Kingdom or the European Economic Area, we will ensure that appropriate safeguards are in place to protect your personal data, as required by applicable data protection laws.
11. International transfers of personal data
In processing your personal data, it will sometimes be necessary for us to transfer your personal data outside of the United Kingdom ("UK") and/or the European Economic Area (“EEA”) to our group companies and our third party service providers.
In connection with such transfers, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and applicable data protection laws. This shall include ensuring that:
- there are appropriate safeguards in place such as binding corporate rules or the standard data protection model contractual clauses between either of us or between us and the recipient; or
- an adequacy decision has been made by the UK or EEA (as applicable) such that the data protection regime in the relevant location or jurisdiction ensures an adequate level of protection for personal data; or
- one of the derogations for specific situations applies.
If you have any questions about our international transfers of personal data, please contact us using the contact details at section 3 of this Privacy Policy.
12. Marketing
As noted in section 7 of this Privacy Policy, we may send you marketing communications about our events and services as well as details of products and services of third parties (such as our exhibitors, sponsors and partners where you have opted in to receive such communications). If you would like to unsubscribe from receiving emails from us, you can click the unsubscribe link in our emails or by contacting us by email at dataprotection@closerstillmedia.com and you can opt out of receiving text messages and/or WhatsApp messages from us by following the instructions on the message you receive to unsubscribe.
You can unsubscribe from emails from third parties by clicking the unsubscribe link in their emails.
13. Your data protection rights
You have the following rights in relation to the personal data we hold about you.
- The right to make a subject access request to be informed of what personal data of yours we hold. If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details).
- The right to have your personal data rectified in the event that it is inaccurate or incomplete. If we have shared your personal data with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we've shared your personal data with so that you can contact them directly.
- The right to request the erasure of your personal data in some circumstances such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.
- The right to object at any time to the processing of your personal data, especially where the processing is carried out for direct marketing purposes. You can ask us to stop processing your personal data, and we will do so, if we are relying on our own or someone else's legitimate interest to process your personal data (except if we can demonstrate compelling legal grounds for the processing) or we are processing your personal data for the purposes of direct marketing.
- The right to restrict the processing of your personal data. You can ask us to 'block' or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we've shared your personal data with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.
- The right to data portability. You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.
- Rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
- The right to withdraw your consent to the processing of your personal data. If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in section 3 above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.
Your rights above can be exercised by contacting us using the contact details set out in section 3 of this Privacy Policy. We may require confirmation of your identity depending on your request.
Should you have any queries or complaints in relation to how we use your personal data, please contact us using the details set out in section 3 of this Privacy Policy. If you wish to take any complaints or queries further, you have the right to contact a national supervisory authority in the place of your residence or the place of the alleged infringement regarding such issues. The data protection supervisory authority in the UK is the Information Commissioner's Office and contact details can be found at https://ico.org.uk/.
14. Security of your personal data
We take precautions to safeguard your personal data against loss, theft and misuse and unauthorised access, disclosure, alteration and destruction through the use of appropriate technical and organisational measures.
All our employees and data processors (i.e. those who process your personal data on our behalf) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data. Our employees are also trained to ensure high levels of security.
We take steps to regularly validate the personal data we hold to ensure that the information is accurate and, where necessary, up to date. Information that is no longer required for any valid business purpose, and that we are not required to keep pursuant to any applicable law, will be routinely destroyed by secure means.
15. Third party links and services
Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal data via these websites. This Privacy Policy shall not apply to the processing of your personal data carried out by a third party provider.
16. Our use of cookies and similar technologies
Our Website may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.
17. Changes to this Privacy Policy
We will update this Privacy Policy from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.
We will notify you by email of any significant changes to this Privacy Policy. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal data.
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