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CloserStill – Privacy Policy

This Privacy Policy sets out how CloserStill Media Limited ("CloserStill", "we", "us", "our") processes your personal data in connection with our services.

 

This Privacy Policy applies to you, the person accessing our services or using our website at https://www.bestpracticelondon.co.uk/ (our "Website").

 

This Privacy Policy was last updated on [8 June 2023].

 

1. Purpose of this Privacy Policy

 

This Privacy Policy explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal data. This Privacy Policy also sets out your rights in respect of our processing of your personal data.

 

When we talk about "personal data", we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them.

 

This Privacy Policy only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you obtain services from those third parties).

 

2. About us

 

Registered Company Name: CloserStill Media Limited
Trading As: CloserStill Media

Company number: 5816917
ICO Registration: Z1479947

Registered Address: CloserStill Media Limited, Exhibition House, Addison Bridge Place, London W14 8XP

CloserStill is the controller responsible for your personal data.

 

3. How to contact us

 

If you have any questions about this Privacy Policy or want to exercise any of your data protection rights, please email us at dataprotection@closerstillmedia.com.

 

4. How we collect and receive personal data

 

We collect and receive personal data using different methods:

 

4.1 Personal data you provide to us:

You may give us your personal data directly. This will be the case when:

  • you submit personal data through our Website;
  • you contact us;
  • personal data is collected from you onsite during our events; and
  • our staff are in direct communication with you or a relevant organisation.

4.2 Personal data we collect using cookies and other similar technologies:

When you access and use our Website, we will collect certain technical information about your equipment, browsing actions and patterns. This will include:

  • personal data gathered from services which use an IP address to determine which organisation visitors to our Website originate from;
  • information from actions made by an individual in response to direct marketing campaigns (including when an individual opens any emails or follows any links originating from our email communications);
  • information related to usage and navigation of our Website; and
  • data used to provide personalised marketing / user experiences while visiting our Website.

4.3 Personal data from third party sources:

We may obtain personal data about you from third party sources including from:

  • partners who we engage with in joint marketing efforts;
  • public data sources used to supplement or validate our existing datasets;
  • data services / suppliers used to obtain or supplement our existing datasets; and
  • data which has been acquired as part of an acquisition or merger.

 

5. Who we collect personal data about

 

We collect and process personal data of individuals who:

  • contact us;
  • use any of our services (for example, attend an event);
  • use, interact, access and browse our Website; or
  • submit a complaint through our Website.

 

6. Personal data we collect

 

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

 

  • Identity Data
    • includes first name, surname, date of birth, student number, photo identification,
  • Visual Data
    • includes photographs and film footage from our events;
  • Contact Data
    • includes address, email address and telephone number;
  • Transaction Data
    • includes details about payments to and from you;
  • Marketing Data
    • includes your preferences in receiving marketing from us and our third parties, your communication preferences and your response to our marketing activities;
  • Professional Data
    • includes details about the organisation that you work for, your professional experience and demographics relating to your professional activity / interests;
  • Website Data
    • includes information about how you use our Website;
  • Special Category Data
    • we may also collect certain special category data. Special Category Data is data which is deemed more sensitive under data protection laws and needs more protection. Although we generally seek to avoid collecting Special Category Data, there are some circumstances in which you may provide it to us (such as when you submit dietary or accessibility requirements). The provision of this information is entirely voluntary and subject to your express consent.

 

7. How we use your personal data and lawful basis

 

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. Please see below for further details about our use of legitimate interests as a lawful basis.

What we use it for Category of data Lawful basis for processing

To communicate with you in regards to our events and services. 

Identity Data

Contact Data

Legitimate interests.

To provide you with information and updates relating to a specific event / service that you have signed up to.

Identity Data

Contact Data

For the performance of a contract between you and CloserStill. 

To enrol you and facilitate your attendance at an event. 

Identity Data

Contact Data

Special Category Data

For the performance of a contract between you and CloserStill.

Express consent.

To send you communications relating to products and services of our affiliates (including exhibitors, sponsors and media partners).

Identity Data

Contact Data

Legitimate interests.

To invite you to take surveys related to our products or the products of our affiliates.

Identity Data

Contact Data

Legitimate interests.

To respond to you in relation to any enquiries you may have.

Identity Data

Contact Data

Legitimate interests.

To produce analytics relating to your usage of our products and response to our marketing activities.

Marketing Data

Legitimate interests.

To create marketing collateral to use on our marketing materials, website and social media.

Visual Data

Legitimate interests.

 

Legitimate Interests

Where we process your personal data based on a legitimate interest, we will only do so where the processing is proportionate and limited to what is necessary for the purpose it was originally collected for. We will also ensure that our legitimate interests do not override your legitimate interests as an individual.

 

If you have previously attended one of our events, subscribed to one of our services or we have made an assessment of your interests based on your profession or industry, then, in the absence of consent, the legal basis on which we have processed your personal data and communicated with you is legitimate interest.  We have a legitimate interest in communicating with you in order to give you information regarding upcoming events or our other services.  In balancing our interests against yours, we take into consideration the facts that the amount of your personal data we process is minimal, that it is not sensitive data, that there is a minimal privacy impact and that you can easily opt out or unsubscribe at any time.

8. If you fail to provide your personal data

 

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide you with access to our services or Website. In this case, we may not be able to provide you with our services or access to our Website, in which case we will notify you.

 

9. How long we will keep your personal data

 

We store your personal data in accordance with applicable law and will not retain your personal data for longer than is necessary unless required to by other legal or regulatory requirements or to enable us to adequately investigate complaints. If you have any questions about the retention of your personal data, please contact us using the details at section 3 of this Privacy Policy.

 

10. Sharing personal data

 

10.1 When we will share your personal data

We will only share your personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations. We may share your personal data where:

  • you have agreed to the sharing of this information:
    • during registration for an event;
    • during form submission; or
    • while attending one of our events, in particular when attending theatres and visiting stands;

 

  • you have agreed to us sharing your name and email address with carefully selected third parties (such as our exhibitors, sponsors and partners) whose products and services may interest you;

 

  • data sharing is required for us to fulfil a contractual obligation we have with you and/or your organisation;

 

  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation; and/or

 

  • we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, in which case we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors.) In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events.

The above list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

 

10.2 Who we will share your personal data with

The third parties that we may need to share your personal data with are as follows:

 

  • exhibitors and sponsors of events that you attend;

 

  • marketing agencies that have booked a stand on behalf of an exhibitor or sponsor of an event that you attend;

 

  • event partners and suppliers: when we run events, we may share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we may share your personal data with such organisations for use in relation to the event;

 

  • third parties (such as our exhibitors, sponsors and partners): who we believe you will benefit from hearing from about their third party products and services (where you have opted in to us sharing your name and email address);

 

  • advertising partners: we may share personal data with third party advertising partners when you use our Website. This data is used to provide you with, and measure the effectiveness of, online personalised advertising and for other advertising related activities;

 

  • third-party email marketing and CRM specialists: we may share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications;

 

  • third-party organisations that provide applications/functionality, data processing or IT services: we may share personal data with third parties who support us in providing the Website and help provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We may also share your personal data with third-party service providers to assist us with insight analytics;

 

  • payment providers and banks: We may share personal data with third parties who assist us with the processing of payments;

 

  • auditors, lawyers, accountants and other professional advisers: We may share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in;

 

  • courts, law enforcement or other government and regulatory agencies and bodies: We may share personal data with courts, law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation; and

 

  • occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Please see list below for names of specific sub-processors that we share your personal data with (note that this list is non-exhaustive and is subject to change):

Sub-processor Name Nature of Processing Website
Amazon Web Services Storage https://aws.amazon.com
Circ Data

GEVME

Delegate and Exhibitor Registration

Delegate and Exhibitor Registration

https://www.circdata.com
https://gevme.com
GES Global Logistics Contractor https://www.ges.com/eu
ASP Solutions Ltd Website Provider https://www.asp.com/contact
Dotdigital Email Marketing Provider https://dotdigital.com
Sector Global

Swapcard

App & Virtual Platform Provider

App & Virtual Platform Provider

https://sectorglobal.com/ 

https://www.swapcard.com/

Salesforce CRM Provider https://www.salesforce.com/uk
Exavault Secure File Transfer https://www.exavault.com/privacy
Presentation Service Providers Ltd Onsite AV Contractor https://pspav.com

 

11. International transfers of personal data

 

In processing your personal data, it will sometimes be necessary for us to transfer your personal data outside of the United Kingdom ("UK") and/or the European Economic Area (“EEA”) to our group companies and our third party service providers.

In connection with such transfers, we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy and applicable data protection laws. This shall include ensuring that:

  • there are appropriate safeguards in place such as binding corporate rules or the standard data protection model contractual clauses between either of us or between us and the recipient; or

 

  • an adequacy decision has been made by the UK or EEA (as applicable) such that the data protection regime in the relevant location or jurisdiction ensures an adequate level of protection for personal data; or

 

  • one of the derogations for specific situations applies.

 

If you have any questions about our international transfers of personal data, please contact us using the contact details at section 3 of this Privacy Policy.

 

12. Marketing

 

As noted in section 7 of this Privacy Policy, we may send you marketing emails about our events and services as well as details of products and services of third parties (such as our exhibitors, sponsors and partners where you have opted in to receive such communications). If you would like to unsubscribe from communications from us you can unsubscribe using the link in our emails or by contacting us by email at dataprotection@closerstillmedia.com.

 

You can unsubscribe from emails from third parties by clicking the unsubscribe link in their emails. 

 

13. Your data protection rights

 

You have the following rights in relation to the personal data we hold about you.

 

  • The right to make a subject access request to be informed of what personal data of yours we hold. If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details).

 

  • The right to have your personal data rectified in the event that it is inaccurate or incomplete. If we have shared your personal data with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we've shared your personal data with so that you can contact them directly.

 

  • The right to request the erasure of your personal data in some circumstances such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

 

  • The right to object at any time to the processing of your personal data, especially where the processing is carried out for direct marketing purposes. You can ask us to stop processing your personal data, and we will do so, if we are relying on our own or someone else's legitimate interest to process your personal data (except if we can demonstrate compelling legal grounds for the processing) or we are processing your personal data for the purposes of direct marketing.

 

  • The right to restrict the processing of your personal data. You can ask us to 'block' or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we've shared your personal data with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal data with so that you can contact them directly.

 

  • The right to data portability. You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

 

  • Rights in relation to automated decision-making and profiling. You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

 

  • The right to withdraw your consent to the processing of your personal data. If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in section 3 above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

 

Your rights above can be exercised by contacting us using the contact details set out in section 3 of this Privacy Policy. We may require confirmation of your identity depending on your request.

Should you have any queries or complaints in relation to how we use your personal data, please contact us using the details set out in section 3 of this Privacy Policy. If you wish to take any complaints or queries further, you have the right to contact a national supervisory authority in the place of your residence or the place of the alleged infringement regarding such issues. The data protection supervisory authority in the UK is the Information Commissioner's Office and contact details can be found at https://ico.org.uk/.

 

 

14. Security of your personal data

 

We take precautions to safeguard your personal data against loss, theft and misuse and unauthorised access, disclosure, alteration and destruction through the use of appropriate technical and organisational measures.

All our employees and data processors (i.e. those who process your personal data on our behalf) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data. Our employees are also trained to ensure high levels of security.

We take steps to regularly validate the personal data we hold to ensure that the information is accurate and, where necessary, up to date. Information that is no longer required for any valid business purpose, and that we are not required to keep pursuant to any applicable law, will be routinely destroyed by secure means.

 

15. Third party links and services

 

Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their related policies. Please check these policies before you submit any personal data via these websites. This Privacy Policy shall not apply to the processing of your personal data carried out by a third party provider.

 

16. Our use of cookies and similar technologies

 

Our Website may use certain cookies, web beacons, pixel tags, log files and other technologies. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

 

17. Changes to this Privacy Policy

 

We will update this Privacy Policy from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.

 

We will notify you by email of any significant changes to this Privacy Policy. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal data.

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