Privacy Policy

Awen Cultural Trust and Awen Trading Ltd (Awen Group) take your privacy very seriously. We are committed to complying with data protection legislation at all times when processing your personal data. We are the data controller of any personal data that you provide to us except for when payment details are provided direct to a payment services provider.

This privacy policy aims to outline how the Awen Group collects, processes and retains the personal data you may provide us when you use of our websites, when you sign up to our emails, or when you buy a product or use a service.

Our websites are not intended for children under 16 years, and we do not knowingly collect data relating to children, except for:

Bridgend Youth Theatre
Young Awen Libraries’ members, which is supplied by the parents/guardians of members
Signing into guest wifi

Who we are

The full legal information is:

Awen Cultural Trust

Registered charity no. 1166908 in Wales

Awen Cultural Trust is a company that is registered in Wales at Bryngarw House, Bryngarw Country Park, Brynmenyn, CF32 8UU Company Registration Number 9610991.

Awen Trading Ltd is a company that is registered in Wales at Bryngarw House, Bryngarw Country Park, Brynmenyn CF32 8UU. Company registration number 09619638.

For the purposes of data protection legislation, the Data Controller is Awen Cultural Trust (ICO registration number ZA186896).

All personal data collected will only be in accordance with this privacy policy

Awen may change this policy from time to time by updating this page and a list of changes is shown in a separate document, which can be requested from the Head of People.

If you have any queries regarding this notice, please email: support@awen-wales.com

Data Controller and Contact Details

Awen (referred to us “we”, “us” or “our” in this notice) is/are the controllers of your personal data.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, like the opportunity to deal with your concerns in the first instance, before you approach the ICO.

Third Party Links

Our websites may include links to third-party websites, plug-ins and applications. By clicking on these links, you may be allowing third parties to collect or share data about you. We do not control these third-party websites and we encourage you to ready the privacy notice of every website you visit.

The Data We Collect

We collect data that is provided by you verbally, digitally and in written form when you: (a) buy tickets or book for our events or workshops; (b) complete forms on our website or in person; (c) make donations; (d) register for a newsletter; (e) apply for a job with us; (f) work for us; (g) volunteer with us; (h) enquire about a wedding, corporate or special occasion booking; (i) stay with us (j) join our library service; (k) attend our trainee service; (l) work for us e.g. freelancers; (m) interact with us through social media, email, post, text or phone, or use one of our cookies; (n) register for and use our guest wifi; (o) agree to be photographed or filmed during or about your experience unless there is a legitimate interest; (p) provide a case study, or (q) complete a survey or feedback questionnaire (unless anonymous).

We may collect, use, retain and transfer the following personal data about you:

Identity data e.g. first name, last name, title.
Contact data e.g. billing address, residential address, telephone numbers, email address.
Financial data e.g. payment card details.
Transaction data e.g. details of tickets, products and services you have purchased or borrowed from us.
Technical data e.g. device MAC address, IP address, browser type, location setting, cookie preferences (see below).
Profile data e.g. username and password, purchase or borrowing history, your interests, survey responses (unless anonymised).
Usage data e.g. how you use and interact with our websites, products and services and your attendance at our events.
Marketing and communications data e.g. if and how you prefer to receive marketing from us and our third parties, and your communication preferences.
CCTV images.

We also collect special category data:

Medical and health information.
Equalities data e.g. ethnicity, disability.

If we want to disclose the candidate’s information to a third party, for example to obtain a reference or to have a disclosure of the Disclosure and Exclusion Service, we will not do so without giving you advance notice, unless the disclosure is required by law.

Why We Need This Information

We will only use your personal data when we are legally allowed to, for instance:

When we need to deliver a contractual service to you e.g. ticket purchase or book loans;
When you have opted in to receive marketing information;
When it is necessary for our legitimate interests and your fundamental rights do not override these interests; and
When we need to comply with a legal or regulatory obligation.

If you fail to provide the data when requested, we may not be able to perform the contract we have, or are trying to enter into with you, for example, where you need to place an order to purchase event tickets. In this instance, we may have to cancel a product or service you have with us.

Under data protection legislation we need a lawful basis in place to process your data. 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 email us at support@awen-wales.com if you would like details about the specific legal ground we are using to process your personal data.

We collect, use and share aggregated data such as statistical or demographic data for monitoring purposes. Aggregated data may be derived from your personal data but it will be anonymised so that it does not directly or indirectly reveal your identity.

How We Collect Your Personal Data

We use different methods to collect data from and about you including:

Direct interactions

You may give us your identity, contact, financial data and special category data by corresponding with us in person, by phone, by email or online via our websites.

This includes when you:

Order tickets;
Reserve or renew a book or other library item;
Create an account on our websites;
Subscribe to our newsletters;
Request for marketing to be sent to you;
Complete a survey or provide feedback;
Arefilmed or photographed;
Provide a case study about your experience;
Apply for a job at Awen;
Volunteer with us;
Are referred to trainee services;
Are part of Accident and incident reporting;
Register for and/or use our guest wifi service;
Provide services e.g. performers, artists; and
Sign up for training or other activities.

Automated technologies or interactions

When you interact with our websites, we may automatically collect technical data about your equipment, browsing behaviour and actions. We collect this personal data using cookies and other similar tracking technologies such as pixels. We use this information to administer our websites, track your movements around our websites, provide targeted advertisements and gather demographic and geographic information about you.

We may receive technical data about you if you visit other websites employing our cookies or tracking technologies, such as the library management system.

Examples of the cookies we use:

Preference cookies – to remember your preferences and settings to provide you with an enhanced service.
Security cookies – for security purposes.
Advertising cookies – to provide you with advertisements that may be relevant to you.
Functional cookies – to provide enhanced functionality and personalisation.
Targeting cookies – to build a profile of your interests and show you relevant adverts on other sites.
Social media cookies – to enable you to share our content with your friends and networks.

You can set your browser to refuse some or all browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly.

Examples of the pixels we use:

When we send email newsletters to our subscribers, the tools we use like Mailchimp and Dotdigital automatically add a ‘pixel’ to provide us with data about ‘open rates’ and ‘click rates’.
Meta pixels are used to ensure we are showing our Facebook, Instagram and WhatsApp ads to the right people and measure the results of these ads by understand what happens when people see them.
Conversion pixels are used to track website purchases, newsletter sign-ups, button clicks, form completions, documents downloads, calls and WhatsApp messages sent to phone numbers on our websites, emails sent to email addresses on our websites.

We may receive personal data about you from various third parties, social media platforms and joint marketing partners, including:

Identity data from Facebook, other ticket agents, Pipedrive, Catersoft.
Contact data from Facebook, Dotdigital, Fydelia, other ticket agents.
Profile data from Facebook, QuestionPro.
Transaction data from Spektrix, SirsiDynix, crowdEngage.

How We Use Your Personal Data

We will use personal data:

To allow us to provide the services and information you have requested from us e.g. tickets, receipts, invoices, trainee services, events, activities etc.;
To enable third parties to process credit card transactions securely, we send your billing information to third parties to process your orders and credit card payments;
To send you service messages, including temporary or permanent changes to our services, and changes to this policy;
To perform the contract we are about to enter into or have entered into with you, and enforce compliance with our terms and conditions;
To help us understand how our websites and services are used;
To enable us to send you communications, either by email or post, that may be of interest to you, in line with your marketing preferences;
To demonstrate your experience/feedback to funding partners and other stakeholders e.g. with case studies, testimonials on film, photographs;
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.
Where we need to comply with a legal, professional, security or regulatory obligation.
Where we need to protect against legal liability and/or protect and defend our rights or property.
CCTV images are held on our cameras to improve safety and help prevent and detect crime and disorder. Due to the nature of Awen services there may also be a reason to use material CCTV for other purposes such as safeguarding adults and vulnerable children or potential criminal activity.
Candidate/personal data is requested regarding candidates to monitor recruitment statistics except where a candidate is successful. When a candidate becomes an employee, the Information provided by them forms part of their personal file. A separate privacy notice is in place for the processing of employee data.
To manage your placement as a trainee and provide the necessary services and support.

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 we need to use your personal data for an unrelated purpose, we will explain the legal basis which allows us to do so.

Marketing

It is your choice whether you receive marketing information from us and you can opt out at any time. We will send you this information by email, post or text message. We may also send you direct mail that we feel may be of interest to you. We will not contact you for marketing purposes unless you have given us your consent. If you no longer wish to hear from us, please send an email to marketing@awen-wales.com.

All of our email marketing gives you the option to opt out of receiving further information from us. As noted above, you will still receive emails from us if needed to deliver a contractual service to you e.g. ticket purchase or book loan, or if you have submitted an online enquiry form and we need to respond.

Analytics

When you visit our website, we use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out such things as the number of visitors to the various parts of the sites. We use the information to report on visitor numbers, and to make improvements to our service.

This information is collected only if visitors opt in. The information collected is classed as personal data because Google assigns a unique identifier to each visitor. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our websites.

Remarketing

We remarket services to advertise on third party websites to you after you have visited our websites. We, and our third-party suppliers, use cookies to inform, optimise and serve ads based on your past visits to our websites.

Google Ads remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/

Facebook’s remarketing service is provided by Meta. You can learn more about interest-based advertising from Facebook by visiting https://www.facebook.com/help/164968693837950.
To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217. For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Photography

We have assessed that our ‘lawful basis’ for photography, videography and sound recording at our public events and venues is one of ‘legitimate interest’. Recorded content may be used for marketing/promotional (digital and traditional) and evaluation purposes. You have the right to opt-out at any time of any photography/videography/sound recording beforehand; please let a member of the Awen team know. You also have a right to object, either before or any time after the image is taken. Where objections are raised afterwards, email marketing@awen-wales.com

Sharing your information

The information you provide to us will be treated as confidential. We may disclose your information to other third parties who act for us for the purposes set out in this policy, for purposes approved by you, in relation to the management of a contractual arrangement or by law, including to suppliers who provide our marketing, financial, ticketing, library management services (including Spektrix, SirsiDynix, Secure My Booking, crowdEngage, Dotdigital, Mailchimp, Pipedrive, Catersoft and Little Hotelier), Local Government Partners or professional bodies and software related to managing your employment.

Information is stored on the servers used by carefully selected third parties and they may be situated inside or outside the UK or European Economic Area.

We only choose partners that we can trust. We will only transfer personal data if they have signed a contract that requires them to:
comply with the requirements of data protection legislation;

treat your information as carefully as we do;
use the information for the purposes for which it was supplied only; and
allow us to carry out checks to make sure they do all these things.

How long we keep your information

We review our data retention periods every 2 years and will only hold your personal data for as long as is necessary for the relevant activity, or as required by law (we may be legally required to hold some types of information), or as set out in any relevant contract we have with you.

Your rights

At any time, you have the right to:
Request access to your personal data (often called a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and check we are processing it lawfully;
Request we correct any incomplete or inaccurate information we hold about you;
Request the removal of your personal data, where there is no good reason for us to continue processing it.
Object to us processing your personal data where we are relying on a legitimate basis lawful basis.
Request the restriction of processing your personal data, for example whilst we are checking the accuracy of it or the reason for processing.
Request the transfer of your personal data to another party (data portability).
Withdraw your consent (e.g. for marketing purposes) at any time.

If you would like to exercise any of your rights above, please contact support@awen-wales.com

If you would like to make a complaint about how we have handled your personal data, you can contact our Head of People who will investigate the matter.

If you are not satisfied with our response or believe that we do not process your personal data in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

Our Head of People is Helen Cook and you can contact her at
Awen Cultural Trust
Bryngarw House
Bryngarw Park
Bridgend
CF32 8UU

Data Security

We have put appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

We are committed to ensuring your personal data is safe. To prevent access or unauthorised disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online against loss, misuse or change.

Examples of our safety include:

Only authorised personnel can access information about consumers, and we use industry standard security technology (such as TLS / SSL, but not limited to it) to encrypt financial and personal data that you input before it be sent to us over the internet.
Third parties will only process your data on our agreement and in line with contracts
Access controlled systems and information through authorised levels and processes.
Where necessary, you will receive a password that allows access to specific systems that hold personal data it is your responsibility to keep this password safe and not to share it with anyone.
We train our staff to make them aware of how to handle information and what to do when things go wrong.
Information is kept for as long as we need it only, unless it needs to be retained for legal purposes or to make sure we will not contact you if you have asked us not to do that.
Customer personal data is kept for as long as we need to provide goods, services or information for you.
Personal / special category information is held in connection with job applicants for a period of 6 months.
CCTV Images – Normal digital recordings will be kept for a period of 31 days on a drive hard or disk and then they will be overwritten.
Except for evidential purposes CCTV images will not be copied. All recorded material provided as evidence is treated in accordance with the procedures defined under the Police and Criminal Evidence Act (PACE)
If you are purchasing your tickets through Spektrix online, our booking pages are encrypted to a high standard meaning that your information is secure and protected against loss or misuse.

Our SirsiDynix Library Management System also uses modern encryption and intrusion prevention techniques.

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.

Changes to our Privacy Policy

Any future changes we make to our privacy policy will be posted on this page and, where appropriate, notified to you by email.

Contact us

Any questions relating to this policy and our privacy practices should be sent to support@awen-wales.com