We are committed to protecting your personal information and to being transparent about what we do.
Purpose of our policy
The Marlowe is committed to protecting your personal information and to being transparent about what we do with the information that we hold about you. We promise to use the information we collect about you in accordance with the General Data Protection Regulation (2018) (GDPR) and the Data Protection Act (2018). We aim to be clear when we handle your data, and not do anything you wouldn’t reasonably expect.
The purpose of this policy is to give you a clear explanation about how we use the information that we collect from you directly, and from third parties.
We use your information in accordance with applicable laws concerning the protection of personal information. This policy explains:
- What information we may collect about you
- How we may use that information
- In what situations we may disclose your details to third parties
- Information about how we keep your personal information secure, how long we retain it for and your rights to be able to access it
If you have any queries about this policy, please contact The Marlowe by emailing Paul Turner.
Who we are
The Marlowe Trust is a charity and is funded by ticket sales and membership income, individual donors, supporters and various trusts and foundations.
The Marlowe Trust also has a commercial trading company called The Marlowe Trust Trading Ltd.
The Marlowe Trust is registered as a company in England and Wales under registration number 11188407, and a UK registered charity no. 1179882. The Marlowe Trust Trading Ltd is registered as a company in England and Wales under registration number 11337139.
We collect customer information in a number of different ways:
Information that you give us
When you register on our website, buy tickets online, by phone or in person, join our membership schemes, contact us by phone, post or email, book for the Green Room, make a donation, or complete one of ours surveys we will store the personal information that you give us including: your prefix and name, email address, date of birth, postal address, billing address, telephone number and payment card details.
We will also store a record of the purchases that you have made with us, or any donations that you have made to support what we do.
If you are involved in an incident that relates to our premises or business, we may collect information from you for incident reporting and investigation purposes and in order to meet our health and safety obligations.
Information about your interactions with us
We collect information about how you interact with us when you visit our website or read our emails. This allows us to monitor how our audiences use our websites, make our communications relevant to you and to understand how we can make them more effective.
Information is collected in the following ways:
- When you visit our website: where we collect information about how you interact with our show pages and content. We may collect your automatically populated IP address which records the date and time of your visit to the website, the referring website (if provided) and your internet browser version.
- When we send you a mailing: where we store a record of this. In the case of emails, we also store a record of which emails you have opened and which links that you have clicked on. This helps us to make sure that our communications with you are relevant and effective.
Information we receive from third parties
In certain circumstances, your information will be shared with us by various third parties in the following ways. For example:
- Service providers: we collect personal information from our payment services providers and booking service agents [and agents who sell tickets on our behalf]. For donors, we sometimes use service providers to verify source of funds as required by law.
- Publicly available information sources: we may combine information you have given to us with information available from external public sources in order to gain a better understanding of our audiences, visitors and supporters to improve our fundraising and marketing methods. This will only be done when you give permission to the relevant third-party organisations to share with us the data they hold on you, or if the data is already publicly available, or if we are required by law or requested by the police or a regulatory or government authority investigating potentially illegal activities. To ensure fundraising is appropriate, we may add publicly available information to your records to create a profile of your interests and level of potential donations to us. These publicly available information sources include:
- Social media: we use social media to broadcast messages and updates about events and news. On occasion we may reply to comments or questions you make to us on social media platforms. You may also see adverts from us on social media that are tailored to your interests. Depending on your settings or the privacy policies of social media and messaging services like Facebook, LinkedIn or Twitter, you might give third parties permission to access information from those accounts or services.
- Information available publicly: this may include information found in places such as Companies House, your biography on your work website or information that has been published in articles/newspapers.
- Google Analytics: Please note that we use Google Analytics on our site to find out about the volume of traffic to our site and our users’ browsing actions and patterns.
This type of profiling allows us to target our resources effectively, to understand the background of the people who attend our theatre, shows and events, and who support us. This helps us to make appropriate requests to customers and supporters who may be able and willing to give more than they already do. We will tell you about current and future fundraising campaigns that we think are relevant to you, and how you can make a difference to our reach and impact through a donation or other involvement. Importantly, it enables us to raise more funds, sooner, and more cost-effectively, than we otherwise would. If you would prefer us not to use your data in this way, you can ask us not to.
Sensitive personal data
Data protection law recognises that certain categories of personal information are more sensitive such as health information, trade union membership, race or ethnicity, religious beliefs, sexual orientation, political opinions, and genetic and biometric data.
We do not usually collect this type of information about our patrons unless there is a clear reason for doing so.
Instances when we collect and store information of this type include:
- Access performances: where customers wishing to book access performances online (such as signed and audio described performances) can choose to register themselves as having a particular access need. This allows our Box Office system to unlock reserved seats in the appropriate areas of the auditorium. However, if a customer does not wish to register their access requirements in this way, they can book their tickets with our Box Office team, by phone or in-person.
- Participation classes: we collect relevant health and access information from participants taking part in our creative classes. This information allows our workshop leaders and creative team to make any reasonable or necessary adjustments to creative classes for the individual. This information is stored in secure drives that are password protected.
How we process your information
We may process your data for the purposes listed below:
We use the lawful basis of performance of a contract for the following:
- When you make a purchase from us you are entering into a contract with The Marlowe. In order to perform this contract we need to process and store your data. We may occasionally need to contact you by email, letter or telephone about your purchase with us, such as confirming your order, in the case of a cancelled show, or should there be problems with your payment.
Joining our membership schemes
- When you join a Marlowe membership scheme, including The Marlowe Friends, The Marlowe Friends Extra, The Marlowe Supporters, The Marlowe Champions, The Marlowe Superstars, The Marlowe Benefactors, The Creative Circle, Business Members, Local Artist Log and Associate Schools, we may contact you by email, letter or telephone with information regarding your membership, such as member benefits. This allows The Marlowe to perform its contract with its members, providing the benefits that are promised. You have the right to object to any of this processing at any time. If you wish to object, please use the contact details provided at the end of this policy. However, if you object this may affect our ability to carry out tasks that are for your benefit.
For any situation where contract purposes or legitimate organisational interest are not appropriate as a lawful basis for the processing of your data, we will instead ask for your consent before using your personal information in that specific situation.
Situations when we use consent to process your data or contact you include:
- Sharing your data with another organisation: We may ask you if you would like your data to be shared with another organisation, such as a visiting theatre company or event organiser. We only do this if you give us your active consent.
- Group booking telephone calls: If you make group bookings for events at our theatre, we may ask you if you would like to be contacted by telephone about forthcoming shows.
- Fundraising information: We may ask you if you would like to receive news and information on fundraising and development initiatives undertaken by The Marlowe.
Legitimate organisational interest
In certain situations we may collect and process your personal information for purposes under the lawful basis of legitimate organisational interest.
However, we only do this if there is no overriding prejudice to you caused by The Marlowe through using your personal information in this way. In these cases we will always keep your fundamental rights and freedoms at the forefront of what we do.
We describe below all of the situations where we may use legitimate organisational interest as the basis for processing your information, or contacting you.
We aim to communicate with you about the work that we do in ways that you find relevant, timely and respectful. To do this, we use data that we have stored about you, such as information on which events you have booked for in the past, as well as any preferences you may have told us about.
We use legitimate organisational interest as the legal basis for sending you marketing communications by post and email. Communications that we send to you may include relevant information about future shows and events, our membership schemes and regular newsletters about the theatre and its future productions.
We may also send information about how you can support The Marlowe on the basis of our legitimate interests to seek support.
Postal mailings: In the case of postal mailings, you can withdraw your consent to receive these mailings at any time by visiting our website or talking to a member of our Box Office team. You can also object to receiving these at any time by using the contact details provided at the end of this policy.
However, we may still contact you by post for matters relating to your purchases (such as in the event of a cancelled performance or a problem with your payment).
Email communications: In the case of email, we will give you an opportunity to opt out of receiving emails during your first purchase with us. If you do not opt out at that point, we will provide you with an option to unsubscribe in every email that we subsequently send you. You can withdraw your consent to receive emails at any time by visiting our website or by talking to a member of our Box Office team. You can also object to receiving these at any time by using the contact details provided at the end of this policy.
However, we may still contact you by email for matters relating to your purchases (such as in the event of a cancelled performance or a problem with your payment).
Telephone contact: We may contact you about our work by telephone however we will always get explicit consent from you before doing this.
You can withdraw your consent to receive phone calls from us at any time by visiting our website or talking to a member of our Box Office team. You can also object to receiving these phone calls at any time by using the contact details provided at the end of this policy.
However, we may still contact you by telephone for matters relating to your purchases (such as in the event of a cancelled performance or a problem with your payment).
Analysis of our postal and email communications
We may analyse data that we hold about you (such as past ticket purchase history) to help us ensure that the content and timing of communications that we send you by post or email are as relevant to you as possible.
We may analyse data we hold about you in order to ensure the safety and security of our services, buildings and people, including to protect against, identify and prevent fraud and unauthorised or illegal activities (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
To ensure the safety of our customers and staff we have CCTV cameras installed inside and outside of our building. The footage from these cameras is stored securely and can only be accessed by identified staff. If you have any questions about this please contact Paul Turner by email.
Analysis of our website
In order to improve our website, we may analyse information about how you use it and how you interact with the show pages and content that it contains.
To allow us to understand more about who we attract to our events and activities we may undertake data analysis and profiling of our customer database. This provides us with generalised information on our audiences, helping us to understand the geographic and demographic trends of the people who participate in what we do.
Profiling helps The Marlowe to understand which segments of our audience database should be targeted with information about a particular show or service offered by The Marlowe. This allows for The Marlowe’s marketing to be more effective at giving the right information to the most relevant customers.
Profiling is undertaken for The Marlowe by third party organisations, including The Audience Agency, TRG, UK Theatre and Purple Seven. This process involves The Marlowe securely sharing its customer data with these organisations.
You have the right to object to this processing at any time. If you wish to object, please use the contact details provided at the end of this policy.
To allow The Marlowe to understand what customers think about the quality of the service that it provides to them, we send daily surveys to customers who have attended our events.
These surveys are undertaken and processed by a third-party organisation, Purple Seven. This process involves The Marlowe securely sharing its data with this organisation. These surveys may include questions about gender, disability, occupation, ethnicity and age. This information is only used for anonymised and statistical purposes, allowing us to understand which audiences we do, and do not, attract. You are not required to supply this information and it is entirely optional as to whether you choose to do so.
The Marlowe may also send surveys to customers to help understand the quality of the service that it provides in other areas of its operation, including The Green Room restaurant, membership schemes and creative classes.
These surveys are undertaken and processed by third party organisations. This process involves The Marlowe securely sharing its data with these organisations for that purpose.
If you would prefer not to be contacted in this way, please inform us by using the contact details provided below.
There are certain circumstances under which we may disclose your personal information to third parties.
These circumstances are:
- To our own service providers who process data on our behalf and on our instructions (for example our ticketing system software, mailing houses, telesales company, insight analysis providers, fundraising prospect research agencies). In these cases, we require that these third parties comply strictly with our instructions and standards for data security, for example around the security of personal data as set out in this policy.
- Where we are under a duty to disclose your personal information in order to comply with any legal obligation (for example to government bodies and law enforcement agencies).
- TTo specific and named visiting theatre companies or event organisers whose performances or events you have attended. In these cases, we will always ask for your explicit consent before sharing your data and we also require that these third parties comply strictly with our instructions and with relevant data protection laws, for example around the security of personal data.
Cookies are small text files that are automatically placed onto your device by some websites that you visit. They are widely used to allow a website to function (for example to keep track of your online shopping basket) as well as to provide website operators with information on how the site is being used.
Your debit and credit card information
If you use your credit or debit card to purchase from us or to make a donation, we will ensure that this is carried out securely and in accordance with the Payment Card Industry Data Security Standard (PCI-DSS).
We optionally allow you to store your card details for use in a future transaction. This is carried out in compliance with PCI-DSS and in a way where none of our staff members are able to see your full card number. We never store your 3 or 4 digit security code.
Our IT infrastructure complies with PCI-DSS and is fully tested with Lloyds Cardnet, our card payment stream provider. Each card payment method within the Marlowe infrastructure has its own unique Merchant ID and all are tested for compliance as per the PCI-DSS standards. We take card payments via the following methods:
- Website – customer entry
- Website – stored card data
- Box office – counter
- Box office – telephone
- Bars and restaurant
Maintaining your personal information
We will keep your information for as long as is reasonably necessary for the purposes we collected it for, including for the purposes of satisfying any legal, regulatory tax, accounting or reporting requirements.
We store your personal information for eight years from the date of your last transaction so that, for any subsequent purchases you make, we are able to link them back to a single unique record that we hold for you on our system.
If you have pledged a legacy to The Marlowe, we will hold your details until notified by your executors.
If there are aspects of your record that are inaccurate or that you would like to remove, you can usually do this by logging into your account via the My Account section of our website. Alternatively, you can contact the Box Office team or use the contact details provided at the end of this policy.
Any objections that you make to any processing of your data will be stored against your record on our system so that we can comply with your requests.
Security of your personal information
We will put in place appropriate safeguards (both in terms of our procedures and the technology that we use) to keep your personal information as secure as possible. We will ensure that any third parties we use for processing your personal information do the same.
We will not usually transfer, process or store your data anywhere that is outside of the European Economic Area. However, if such processing does take place, The Marlowe will take steps to ensure that your privacy rights continue to be protected as outlined in this policy.
Your rights to your personal information
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have a right to:
- Request a copy of the personal information that we hold about you and to have any inaccuracies in this data corrected.
- Request erasure of your personal data where there is no good reason for us to continue processing it.
- Be informed of the ways in which we use your information.
- Ask us not to process your personal data for marketing purposes.
- Withdraw your consent for our use of your information at any time.
Please use the contact details provided at the end of this policy if you would like to exercise this right or request that we stop contacting you at any time. We will comply with your requests unless we have a lawful reason not to do so.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Your right to complain
You have a right to complain where you believe any misuse of your data has taken place. The UK Information Commissioner’s Office can be contacted directly if you believe that we have failed to address your concerns.
Their information may be found at www.ico.org.uk
Contact details and further information
Chief Finance Officer
KENT CT1 2AS