The Pink Festival Group respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and/or use our app and tells you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy policy gives you information on how The Pink Festival Group collects and processes your personal data through your use of this website and/or our applications, including any data you may provide through this website and/or our applications when you sign up to our newsletter, sign up for our events, sign up to volunteer, take part in a parade, or donate to us.

It is important that you read this privacy policy carefully together with any other privacy policy or fair processing notice 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. This privacy policy supplements the other notices and is not intended to override them.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to data protection laws applicable in the United Kingdom and we are responsible as ‘controller’ of that personal data for the purposes of those laws.

1.1 YOUR DUTY TO INFORM US OF CHANGES

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.

1.2 THIRD-PARTY LINKS

This website and/or our app 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 policies. When you leave our website or our app, we encourage you to read the privacy policy of every website you visit.

1.3 KEY TERMS

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means freely given, specific, informed and unambiguous indication of a data subject’s wishes which is indicated by a positive action.

External Third Parties means:

Legitimate Interest means the interest of our organisation in conducting and managing our business to enable us to give you the best service 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.

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. We, us, our means The Pink Festival Group, a community interest company and Registered Charity (registered number 1163298) and having its registered office at Office A, The Marlborough Club, High Street, Newmarket, CB8 8UG.

1.4 THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where it is no longer possible to identity the person (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or app 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.

1.5 HOW IS YOUR PERSONAL DATA COLLECTED?

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

2. HOW WE USE YOUR PERSONAL DATA

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:

See section 1.3 of this policy above find out more about the types of lawful basis that we will rely on to process your personal data.

Generally we do not rely on consent as a legal basis for processing your personal data. You have the right to withdraw consent to marketing, and your participation of surveys or research at any time by contacting us, for our contact details, see below.

3. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below 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.

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 where more than one ground has been set out in the table below.

PURPOSE/ACTIVITYTYPE OF DATALAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST
To enable you to:

volunteer with us;
attend and participate in our festivals and parades and other events (e.g. march in a parade or host a stall at our events);
donate to us; and
to enable us to Manage payments, fees and charges and collect and recover money owed to us.
Identity
Contact
Financial
Transaction
Marketing and Communications
Performance of a contract with you
Necessary for our legitimate interests (to recover debts due to us, and to promote and support the LGBTQ community)
To allow you to sign up for our mailing list, or, remove you where you no longer wish to receive our updatesIdentity
Contact
Profile
Marketing and Communications
Consent
To manage our relationship with you which will include:

notifying you about changes to our terms or privacy policy; and
any other activity relating to the management of our relationship with you.
Identity
Contact
Profile
Marketing and Communications
Performance of a contract with you
Necessary to comply with a legal obligation
Necessary for our legitimate interests (to keep our records updated)
To administer and protect our organisation and this website and/or our app (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)Identity
Contact
Technical
Necessary for our legitimate interests (for running our organisation, provision of administration and IT services, network security, to prevent fraud)
Necessary to comply with a legal obligation
To deliver relevant website and/or app content and advertisements to you and measure or understand the effectiveness of the advertising we serve to youIdentity
Contact
Profile
Usage
Marketing and Communications
Technical
Necessary for our legitimate interests (to study how users of our website and/or our app use our services and to inform our marketing strategy)
To use data analytics to improve our website and/or our app, events, products and services and marketingTechnical
Usage
Necessary for our legitimate interests (to develop our products/services and grow our organisation)
To enable you to take part in our surveys and research and to allow us to report on the outcome of our research.Identity
Contact
Technical
Usage
Profile
Aggregated Data
Sensitive Personal Data
Consent

4. MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you change your mind and no longer wish to receive such communications or wish to change your preferences, you can opt out at any time by contacting us using the details provided below.

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).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

5. THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.

6. OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

7. CHANGE OF PURPOSE

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. 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. 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.

8. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in section 3 above.

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.

9. DATA SECURITY

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, volunteers, 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. 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.

10. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. In some circumstances you can ask us to delete your data, for more information see section 12 below. In some circumstances we may 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.

11. INFORMATION ABOUT OUR USE OF COOKIES

Our website and/or our app uses cookies to distinguish you from other users of our website or app. This helps us to provide you with a good experience when you browse our website and/or use our app and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you disable or refuse cookies, please note that some parts of this website and /or our app may become inaccessible or not function properly.

12. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. In particular, you have the following rights which you can exercise free of charge, by contacting us via the details below:

Access – The right to be provided with a copy of your personal data (the right of access).

Rectification – The right to require us to correct any mistakes in your personal data.

To be forgotten – The right to require us to delete your personal data—in certain situations.

Restriction of processing – The right to require us to restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability – The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object – The right to object:

Not to be subject to automated individual decision-making – The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

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 may refuse to comply with your request in these circumstances.

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.

We try to respond to all legitimate requests within one month. Occasionally it may 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.

13. HOW TO CONTACT US

Please contact us and/or our Data Protection Officer by post or email if you have any questions about this privacy policy or the information we hold about you using the details shown below:

The Pink Festival Group (FAO: Data Protection Officer)
Office A, The Marlborough Club, High Street, Newmarket, CB8 8UG
hello@cambridgepride.co.uk

Adam Olivant, Data Protection Officer,
The Pink Festival Group
Office A, The Marlborough Club, High Street, Newmarket, CB8 8UG
dpo@pinkfestival.co.uk

14. CHANGES TO OUR PRIVACY POLICY

This version was last updated on 24 May 2018 and historic versions can be obtained by contacting us at the details provided above.

15. HOW TO COMPLAIN

We hope that our Data Protection Officer can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at http://ico.org.uk/concerns or telephone: 0303 123 1113.