FLEUR ESTELLE BELLY DANCE LIMITED
We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
It would be helpful to start by explaining some key terms used in this policy:
Personal data: Any information relating to an individual or identifiable individual
Special category personal data: According to the GDPR this is “Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation”
However, in normal circumstances the only special category data that we will collect is that relating to health issues we need to know about, for example, details of any illnesses or injuries the instructor will need to know about the person partaking in a class.
Who we are
Fleur Estelle Belly Dance Limited (Company Number 07283237) whose registered office is at 585a Fulham Road, London SW6 5UA trading as Fleur Estelle, Fleur Estelle Belly Dance, Fleur Estelle Dance School and Fleur Estelle School collects, uses and is responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The personal information we collect and use
Information collected by us
- In the course of booking a show, booking tickets to one of our shows or subscribing to our newsletter, we collect the following personal information when you provide it to us:
address and billing and delivery address (as applicable);
photographs or videos of our shows you attend
- In the course of enrolling in classes with us, we collect the following personal information when you provide it to us:
name of person making the booking, and the name of the person to attend the course of classes if different from the person making the booking;
address and billing and delivery address (as applicable);
date of birth;
name and contact details of the person we should contact in the event of emergencies;
information regarding any health issues we need to know about, for example, details of any illnesses or injuries the instructor will need to know about the person partaking in a class;
photographs or videos of the classes you attend and shows you take part in;
Information collected from other sources
We use SagePay to process any payments made through our website. We never receive your credit card details but we may obtain personal information from SagePay such as the names of those who have paid using this method.
How we use your personal information
We use your personal information to:
- provide our services to you, either classes or shows;
- comply with our legal obligations, including complying with our health and safety obligations;
- in the event of an emergency, contact the person the name and contact details of whom you have provided;
- sending details of classes and other important information regarding classes you have enrolled in;
- sending details of shows or performances you have booked or booked tickets for;
- statistical analysis to help us manage our business e.g. in relation to our customer base, popularity or classes and shows;
- updating our customer records;
- statutory returns;
- marketing our services including sending publications including our email newsletter;
- external audits and quality checks;
- promote our business.
Who we share your personal information with
We routinely share your personal data with Go Daddy, Mad Mimi, Google Drive, Google mail, Google Analytics, SagePay and our freelance teachers and administrators. Some of those third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.
We only allow our service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data.
We may also share personal information with law enforcement or other authorities if required by applicable law.
Whether information has to be provided by you, and if so why
The provision of your personal data referred to above is required from you to enable us to provide our services to you. We will inform you at the point of collecting information from you, what information you are required to provide which will depend upon the service we are providing to you.
How long your personal information will be kept
We will hold:
- name, address and contact details for the period we are required to retain this information by applicable UK tax law (currently 6 years)
- special category data such as details of illnesses or injuries for such time as the injury or illness persists or you are no longer attending classes and for 4 years afterwards;
- photographs and videos for such time as they appear on our promotional material, our website, social media and possibly other websites for as long as such photographs and videos are relevant which may be a minimum of 10 years.
Reasons we can collect and use your personal information
We rely on legitimate business interest as the lawful basis on which we collect and use your personal data. Our legitimate interests are:
- for the performance of our contract with you or to take steps at your request before entering into a contract
making sure we provide you with the best possible service;
- making sure we keep in touch with our customers about existing and new services and any promotions;
promoting our business;
- to comply with our legal and regulatory obligations.
The above list does not include special category data which will only be processed with your consent. However, in normal circumstances the only special category data that we will collect is that relating to health issues we need to know about, for example, details of any illnesses or injuries the instructor will need to know about the person partaking in a class.
Transfer of your information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data with our service providers located outside the European Economic Area (EEA). For example any servers located outside the EEA used by Google Drive and/or Mad Mimi and the availability of photographs and videos on our website, social media and possibly other websites which are available worldwide.
These transfers are subject to special rules under European and United Kingdom data protection law.
Certain countries do not have the same data protection laws as in the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.
Photographs and videos
We take photographs and videos in the following circumstances:
- during a class when a new piece of choreography or new movement is taught so that it can be viewed by students of that class via a private link on Google Drive, occasionally a segment of this may be published on social media;
- during the last week of term a class photograph and/or video is taken which is posted on our website, social media and possibly other websites;
- videos of instructors are occasionally taken during class and posted on social media in which students can sometimes be seen in mirrors on partly in shot;
- during, before and/or after the end of term show professional photographs and videos are taken and posted on our website, social media and possibly other websites;
If photographs or videos are to be taken during a class you will be notified and can decline to take part in the class.
During the course of our business we use each end of term performance to demonstrate the progress that you have made.
Those performances are photographed and videoed and the resultant images will be available on our website, social media and possibly other websites in any event. If you do not wish that to happen you should of course not take part in such performances and please do let us know.
Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:
- fair processing of information and transparency over how we use your use personal information
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
- require us to correct any mistakes in your information which we hold
- require the erasure of personal information concerning you in certain situations
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
- object at any time to processing of personal information concerning you for direct marketing
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal information
- otherwise restrict our processing of your personal information in certain circumstances
- claim compensation for damages caused by our breach of any data protection laws
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us
- let us have enough information to identify you e.g. full name, address and date of birth,
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
- let us know the information to which your request relates, including any account or reference numbers, if you have them
If you would like to unsubscribe from any email newsletter you can also click on the ‘unsubscribe’ button at the bottom of the email newsletter. It may take up to 7 days for this to take place.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that we can resolve any query or concern you raise about our use of your information. (Email us at firstname.lastname@example.org)
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 https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
Changes to this privacy notice
This privacy notice was published on 24th May 2018
We may change this privacy notice from time to time, when we do we will inform you via email (if you are on our opt-in list). In addition the amended policy will appear on our website here.
How to contact us
Please contact us if you have any questions about this privacy notice or the information we hold about you.
If you wish to contact us, please send an email to email@example.com.