INTRODUCTION
Welcome to Leadmyevent's privacy policy.
We respect Your privacy and are committed to protecting Your personal data and, where applicable, that of your representatives. We are committed to processing Your personal data lawfully, fairly, and in a transparent manner and otherwise in accordance with the Data Protection Legislation. This privacy policy will inform You as to how We look after Your personal data when You visit the Platform and tell You about Your privacy rights and how the law protects You.
Unless otherwise stated, the definitions used in the main body of Our Terms apply to this privacy policy. Please also use the Glossary to understand the meaning of some other specific terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
1.1 PURPOSE OF THIS PRIVACY POLICY
1.1.1 This privacy policy aims to give You information on how Leadmyevent collects and processes Your personal data through Your use of the Platform as well as any communication and dealings between: (1) Us and Users; (2) Us and Members; and (3) Users and Members including any data You may provide through the Platform when You sign up as a Member and use the Platform and the Services.
1.1.2 The Platform is not intended for children and we do not knowingly collect data relating to children.
1.1.3 It is important that You read this privacy policy together with any other privacy policy or fair processing policy We may provide on specific occasions when We are collecting or processing personal data about You so that You are fully aware of how and why We are using Your data, including, without limitation, at certain points during the user journey of the Platform and/or when You use certain functionality of the Platform and the Services. This privacy policy supplements other notices and privacy policies and is not intended to override them.
1.2 LEADMYEVENT IS THE CONTROLLER
1.2.1 Leadmyevent Limited trading as "Leadmyevent" is the controller and
responsible for Your personal data ("We"/"Us"/"Our" in this privacy policy).
1.2.2 We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If You have any questions about this privacy policy, including any requests to exercise Your legal rights, please contact the data privacy manager using the details as follows:
• Email info@Leadmyevent.com, marked for the attention of the Leadmyevent Legal Team.
• Postal address: LEADMYEVENT LIMITED
71-75 Shelton Street, London, Greater London, United Kingdom,
WC2H 9JQ
1.3 CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
1.3.1 We keep our privacy policy under regular review. This version was last updated on 1 December 2020. Historic versions can be obtained by contacting Us.
1.3.2 It is important that the personal data We hold about You is accurate and current. Please keep Us informed if Your personal data changes during Your relationship with Us.
1.4 THIRD-PARTY LINKS
The Platform may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. We do not control these third-party websites and are not responsible for their privacy statements. When You leave our Platform, we encourage You to read the privacy policy of every website You visit.
2. THE DATA WE COLLECT ABOUT YOU
2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 We may collect, use, store and transfer different kinds of personal data about you which we
have grouped together as follows:
2.2.1 "Identity Data" includes first name, maiden name, last name, username or similar identifier, title, job title, date of birth and gender, photograph or avatar. This category of personal data includes personal data that You may be invited to provide in the 'My Profile' area of the Platform and other Member Content.
2.2.2 "Contact Data" includes billing address, trading address, email address and
telephone numbers.
2.2.3 "Financial Data" includes bank account and payment card details.
2.2.4 "Transaction Data" includes details about payments to and from You and details of Listings posted and/or Agreements entered into and/or Enquiries made.
2.2.5 "Technical Data" includes internet protocol (IP) address, Your login data, browser type and version, referring URLs, page views, access times, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices You use to access the Platform.
2.2.6 "Profile Data" includes Your username and password, Listings posted and/or Agreements entered into by or on behalf of You, Your interests, preferences, feedback and survey responses, reviews/ratings and, where applicable, cancellation policy/history, compliance with response time service levels, host response rate, host response speed, number of open (not declined, not closed, not accepted) enquiries.
2.2.7 "Usage Data" includes information about how You use the Platform, and the
Services and interact with Us and Members.
2.2.8 "Marketing and Communications Data" includes Your preferences in receiving marketing from Us and our third parties and Your communication preferences including from/to Members.
2.2.9 We also collect, use and share "Aggregated Data" such as statistical or demographic data for any purpose. Aggregated Data could be derived from Your personal data but is not considered personal data in law as this data will not directly or indirectly reveal Your identity. For example, We may aggregate Your Usage Data to calculate the percentage of Users accessing a specific Platform feature. However, if We combine or connect Aggregated Data with Your personal data so that it can directly or indirectly identify You, we treat the combined data as personal data which will be used in accordance with this privacy policy.
2.2.10 We do not collect any "Special Categories of Personal Data" about you (this includes details about Your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about Your health, and genetic and biometric data). Nor do We collect any information about criminal convictions and offences.
2.3 IF YOU DO NOT PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract We have with You, and You fail to provide that data when requested, We may not be able to perform the contract We have or are trying to enter into with You (for example, to provide You with Services or specific Platform features). In this case, We may have to cancel or withdraw all or an element of the Services but We will notify You if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
3.1 We use different methods to collect data from and about You including through:
3.1.1 Direct interactions. You may give Us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with Us by post, phone, email, on the Platform or otherwise or by interacting with other Members on or via the Platform and its functionality. This includes personal data You provide in the following circumstances:
(a) when you:
(i) use our Services or any of them (including Subscription
Services);
(ii) create an Account on the Platform;
(iii) subscribe to our Service, newsletters or publications;
(iv) provide Member Content;
(v) request marketing to be sent to You;
(vi) interact and communicate direct with other Members (via the
messaging functionality);
(vii) enter a competition, promotion or survey; or
(viii) give Us feedback or contact Us.
(b) Service Suppliers are invited to provide as much information as needed to publish their Service Listing which includes, names, photos, descriptions, amenities, FAQs, contact details, social media links, and prices. This can be edited in the My Listings area of the Platform.
(c) Service Suppliers and Event Organisers using the Platform to monitor and respond to enquiries and manage bookings are automatically making their messages and offers visible to the other party. This information is visible to the Leadmyevent Customer Success Team, but is not made available to any other user.
(d) If You contact Us, we may keep a record of that correspondence.
(e) Members’ personal data may be contained in the content of communications between Members and Leadmyevent and between a Member or user and another Member or user via the messaging application. If and to the extent that You access and process personal data of a Member or their representative(s) or any other person You agree that You will do so in a lawful, fair and transparent manner and strictly in accordance with the Data Protection Legislation and, without limitation, You shall ensure that You have legitimate grounds under the Data Protection Legislation for the processing of such personal data.
3.1.2 Automated technologies or interactions. As you interact with the Platform, we will automatically collect Technical Data about Your equipment, browsing actions and patterns. We collect this personal data by using cookies, security tokens, server logs and other similar technologies. We may also receive Technical Data about You if You visit other websites employing our cookies. Please see our cookie policy clause 4.11 for further details.
3.1.3 Third parties or publicly available sources. We will receive personal data about You from various third parties and public sources as set out below: Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) via social media platforms such as Facebook and communications/search networks such a Google/Gmail via which You may elect to login automatically to the Platform (who may be based outside the EU; and
(c) search information providers such as Google based outside the EU.
(d) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as our Payment Processors Stripe and GoCardless who may be based outside the EU.
(e) Identity Data and Contact Data from publicly available sources such as
publicly available websites or Companies House based inside the EU.
(f) Help Scout is a tool for providing customer service – if You use the chat
feature, We ask for Identity Data and Contact Data.
4. HOW WE USE YOUR PERSONAL DATA
4.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
4.1.1 Where we need to perform the contract we are about to enter into or have entered into with you.
4.1.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
4.1.3 Where we need to comply with a legal obligation.
4.1.4 Where we need to share your name and contact with a Service Supplier or Event Organiser to arrange a booking.
4.2 See clause 10.1 to find out more about the types of lawful basis that we will rely on to process your personal data.
4.3 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
4.4 Where We have given You (or where You have chosen) a password which enables You to access certain parts of Leadmyevent, You are responsible for keeping this password confidential. We ask You not to share a password with anyone.
4.5 Financial Data
4.5.1 We do not store any personal credit or debit card details. Any debit or credit card transactions are carried out by reputable third parties (Our Payment Processors) and only they will hold Your details.
4.5.2 We will store bank account details (name, account number, sort code, VAT number where relevant, company registration number where relevant) for Members, where required, such that funds can be sent on to You without delay.
4.5.3 Where You provide such details they will be stored only on the device You use to access Leadmyevent and will not be stored or processed by Us in any way except where You request Us to do so.
4.5.4 Where Financial Data is processed it is only done so for purpose of processing Your Booking. When using Leadmyevent You may also be prompted to provide your credit or debit card details by way of an auto-fill feature.
4.6 PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
4.6.1 We have set out below, in a table format, a description of all the ways We plan to use Your personal data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are where appropriate.
4.6.2 Note that We may process Your personal data for more than one lawful ground depending on the specific purpose for which We are using your data. Please contact Us if You need details about the specific legal ground We are relying on to process Your personal data.
4.7 MARKETING
We strive to provide You with choices regarding certain personal data uses, particularly around marketing and advertising. You can view and make certain decisions about Your personal data use by accessing your Profile or clicking on a relevant link in certain communications that We may send to You.
4.8 PROMOTIONAL OFFERS FROM US
4.8.1 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what We think You may want or need, or what may be of interest to You. This is how We decide which products, services and offers may be relevant for You (We call this marketing).
4.8.2 You will receive marketing communications from Us if You have requested information from Us or purchased from or used the Platform and/or the Services and you have not opted out of receiving that marketing.
4.8.3 Where you have opted-in or as permitted by law, to send You marketing emails, typically sent weekly, from a Leadmyevent address regarding Our services or those of Our partners, We use automation tools to select the most appropriate audience for each marketing email newsletter and personalise the content You receive by automatically remembering information from previous searches, enquiries and bookings.
4.9 THIRD-PARTY MARKETING
We will get your express opt-in consent before We share Your personal data with any third party for marketing purposes.
4.10 COOKIES
4.11.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Platform may become inaccessible or not function properly. For more information about the cookies we use, please see below.
4.11.2 We use cookies and tracking tools to distinguish You from other users of the Platform. A cookie is a small file, typically of letters and numbers, downloaded on to a device when the user accesses certain websites. Cookies are then sent back to originating website on each subsequent visit. Cookies are useful because they allow a website to recognise a user’s web browser or device. This helps Us to provide You with a good experience when You browse the Platform and also allows us to improve Our Platform and the Services and Our marketing activities.
4.11.3 The Platform makes use of both ‘session’ and ‘persistent’ cookies. ‘Session’ cookies remember information from page to page for filtering and completing searches before being removed when You end Your session. ‘Persistent’ cookies enable the Platform to recognise You when You make return visits to Us, and remain stored on Your computer until deleted, or until they reach a specified expiry date.
4.11.4 If You wish to delete cookies after sign up, You can visit www.aboutcookies.org which contains information on how to do this on most browsers. You can also find details on how to delete cookies from Your computer as well as more general information about cookies. For information on how to do this on the browser of Your mobile phone you will need to refer to your handset manual. If these sites do not resolve any issues or questions, please contact hello@Leadmyevent.com and we will be pleased to provide more information or assist.
4.12 We use the following types of cookies:
4.12.1 We use cookies to make sure the Platform performs as it needs to, and to make sure the correct search results are being delivered in accordance with Your selections. We also use cookies to heighten Your experience by recognising whether You are a first time visitor and remembering Your preferences (such as your login username, favourites or booking history) and previous searches.
4.12.2 Optimisation cookies allow Us to see and track anonymous use data such as click trends, so We can be certain the Platform offers You a consistently smooth, functional and pleasant experience. We use third party service providers to assist Us with optimisation, including but not limited to the following:
(a) Helpscout (helpscout.com/company/legal.privacy)
(b) Google Tag Manager (policies.google.com/privacy)
(c) Mailchimp (mailchimp.com/legal/privacy)
(d) Sleeknote (sleeknote.com/privacy-policy)
(e) Smartlook (smartlook.com/help/privacy-statement)
(f) Wordpress (en-gb.wordpress.org/about/privacy)
The Privacy Policy of each third party provider is enclosed in brackets.
4.12.3 We also use cookies to monitor and understand more about how the Platform and Services are used and accessed, which in turn lets Us optimise the user experience and build a solution that suits the needs of Our users and drive the direction of Our business. We use Google Analytics who store cookies on Your device to generate anonymous reports and statistics. Google stores this information in accordance with their privacy policy (policies.google.com/privacy).
4.12.4 Cookies are also set when You use any of the social media sharing buttons on the Platform (to post on Facebook, for example). Leadmyevent does not have control over the cookie policies of third-party social media sites.
4.12.5 If you have any issues or questions regarding cookies, please contact info@Leadmyevent.com and we will be pleased to provide more information or assist.
4.12.6 In order to provide you with a useful social experience when using Leadmyevent, We may give You the option to export information to third party applications and websites, including social networking sites such as LinkedIn, Facebook or Twitter. When exporting such information You may be disclosing Your information to the individuals or organisations responsible for operating and maintaining such third party applications and sites and that Your information may be accessible by others visiting or using those applications or sites. We do not own or operate the applications or websites that You connect with and You should review the privacy policies of such websites to make sure you are comfortable with the ways in which they use the information you share with them.
4.13 CHANGE OF PURPOSE
4.13.1 We will only use Your personal data for the purposes for which we collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
4.13.2 If we need to Use your personal data for an unrelated purpose, We will notify You and We will explain the legal basis which allows Us to do so.
4.13.3 Please note that We may process Your personal data without Your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
5.1 We may share Your personal data with the parties set out below for the purposes previously mentioned.
5.2 External Third Parties as set out in the Glossary.
5.3 Third parties to whom we may choose to sell, transfer or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use Your personal data in the same way as set out in this privacy policy.
5.4 We require all third parties to respect the security of Your personal data and to treat it in accordance with the law. We do not allow Our third-party service providers to use your personal data for their own purposes and only permit them to process Your personal data for specified purposes and in accordance with Our instructions.
6. DATA SECURITY
6.1 We have put in place appropriate security measures to prevent Your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process Your personal data on our instructions and they are subject to a duty of confidentiality.
6.2 We have put in place procedures to deal with any suspected personal data breach and will
notify You and any applicable regulator of a breach where We are legally required to do so.
6.3 Unfortunately, the transmission of information via the internet can never be completely secure. Although We will do Our best to protect your personal data, We cannot guarantee the security of Your data transmitted to the Platform and the Services.
7. DATA RETENTION
7.1 HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
8.1.1 We will only retain Your personal data for as long as reasonably necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain Your personal data for a longer period in the event of a complaint or if We reasonably believe there is a prospect of litigation in respect to our relationship with You.
7.1.2 To determine the appropriate retention period for personal data, We consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of Your personal data, the purposes for which We process Your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We keep basic information about Our Members (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being Members for the above purposes.
7.1.3 In some circumstances you can ask Us to delete Your data: see your legal rights
below for further information.
7.1.4 In some circumstances We will anonymise Your personal data (so that it can no longer be associated with You) for research or statistical purposes, in which case We may use this information indefinitely without further notice to You.
8. YOUR LEGAL RIGHTS
8.1 Under certain circumstances, You have rights under data protection laws in relation to Your personal data. Please refer to paragraph 10 for more information on how to request access, correction, erasure of your personal data.
8.2 If you wish to exercise any of the rights set out above, please contact
info@Leadmyevent.com, marked for the attention of the Leadmyevent Legal Team..
8.3 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.
8.4 WHAT WE MAY NEED FROM YOU
We may need to request specific information from You to help us confirm your identity and ensure Your right to access your personal data (or to exercise any of Your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact You to ask you for further information in relation to Your request to speed up Our response.
8.5 TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. GLOSSARY
9.1 LAWFUL BASIS
9.1.1 "Legitimate Interest" means the interest of Our business in conducting and managing Our business to enable Us to give You the best service/product and the best and most secure experience. We make sure We consider and balance any potential impact on You (both positive and negative) and Your rights before We process Your personal data for Our legitimate interests. We do not use Your personal data for activities where Our interests are overridden by the impact on You (unless we have Your consent or are otherwise required or permitted to by law). You can obtain further information about how We assess Our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
9.1.2 "Performance of Contract" means processing Your data where it is necessary for the performance of a contract to which You are a party or to take steps at your request before entering into such a contract.
9 .1.3 "Comply with a legal obligation" means processing Your personal data where it is necessary for compliance with a legal obligation that We are subject to.
9.2 THIRD PARTIES - EXTERNAL THIRD PARTIES
9.2.1 Service providers set out in paragraphs 3.1.3 and 4.12.2 and otherwise as detailed in this privacy policy.
9.2.2 Service providers acting as processors who provide IT and system administration services including our Payment Processors (www.stripe.com and PayPal)
9.2.3 Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
9.2.4 HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
10. YOUR LEGAL RIGHTS
10.1 You have the right to:
10.1.1 "Request access" to Your personal data (commonly known as a "data subject access request"). This enables You to receive a copy of the personal data We hold about You and to check that We are lawfully processing it.
10.1.2 "Request correction" of the personal data that We hold about You. This enables You to have any incomplete or inaccurate data We hold about You corrected, though We may need to verify the accuracy of the new data You provide to Us.
10.1.3 "Request erasure" of Your personal data. This enables You to ask Us to delete or remove personal data where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove Your personal data where You have successfully exercised Your right to object to processing (see below), where We may have processed Your information unlawfully or where We are required to erase Your personal data to comply with local law. Note, however, that We may not always be able to comply with Your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of Your request.
10.1.4 "Object to processing" of Your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about Your particular situation which makes You want to object to processing on this ground as You feel it impacts on Your fundamental rights and freedoms. You also have the right to object where We are processing Your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process Your information which override Your rights and freedoms.
10.1.5 "Request restriction of processing" of Your personal data. This enables You to ask Us to suspend the processing of Your personal data in the following scenarios:
(a) If You want Us to establish the data's accuracy.
(b) Where Our use of the data is unlawful but You do not want Us to erase it.
(c) Where You need Us to hold the data even if We no longer require it as
You need it to establish, exercise or defend legal claims.
(d) You have objected to Our use of your data but We need to verify whether
We have overriding legitimate grounds to use it.
10.1.6 "Request the transfer" of Your personal data to You or to a third party. We will provide to You, or a third party You have chosen, Your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
10.1.7 "Withdraw consent at any time" where We are relying on consent to process Your personal data. However, this will not affect the lawfulness of any processing carried out before You withdraw your consent. If You withdraw Your consent, We may not be able to provide certain products or services to You. We will advise you if this is the case at the time You withdraw Your consent.