Privacy Policy - The Swell Season

PRIVACY POLICY – ATC MANAGEMENT

 

This privacy policy relates to how we will treat the personal information which you provide to us while using the website located at www.theswellseason.com (“Site”) and/or the services provided by the Site including the mailing list (“Services”). 

 

The Site is provided by ATC Management (“we”, “our” or “us”). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). 

Given the nature of our website, we do not expect to collect the personal data of anyone under [13] years old. If you are aware that any personal data of anyone under [13] years old has been shared with our website please let us know so that we can delete that data.

This version of our privacy policy is primarily written for adults, including parents and guardians of child users. If you are a child (under 18 years old) you are welcome to read this policy if you find it useful, but we recommend you click [here] to see the key information in a form written for kids.

 

 

We explain below how and why we and our third-party service providers process personal data in connection with your use of the Site and Services.

 

If you have questions related to this privacy policy, please contact us:

  • By email: [email protected] 
  • By post: c/o The Hat Factory, 166-168 Camden Street, London NW1 9PT, United Kingdom




Contents [MAKE INTO LINKS]

  • Information we collect about you
  • How we collect personal information
  • How we store your information
  • Your right to object
  • How we use information about you
  • Marketing
  • Access to your information and correction
  • Cookies
  • Third parties
  • Disclosure of your information to third parties
  • Other websites
  • Changes to our privacy policy
  • How to contact us

 

Information we collect about you

We collect information about you when you voluntarily subscribe to our mailing list through the means set out below. We also collect information when you voluntarily complete customer surveys, provide feedback and participate in promotions and competitions. Website usage is information collected using cookies (which we explain more about, below).

This information may include:

    • Your name
    • Your email address
    • Your country
  • Your IP address


We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.


How we collect personal information

We collect personal data from you in the following ways:

  •           directly, when you enter or send us information, such as when you register to register to receive our mailing list, contact us (including via email), and complete customer surveys or participate in competitions via our website, and
  •           indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below



How we store your information

We store your personal data using secure third party data processors, including OpenStage (you can read about OpenStage’s privacy policy here GDPR – Openstage).  When we export your data to local hard drives for processing, we delete the data as soon as processing is complete. 

 

Through our use of data processors, your data may be transferred internationally. Where this is the case, we do our best to ensure that the data processors are compliant with data protection rules. 

 

If you do not open a marketing email from us in 24 months, we will remove you from our list and we will email you to let you know we have done this, together with an option to resubscribe. 

 

Your right to object

 

Your rights

    • Right of access: you have the right to information regarding the data we process concerning you. Upon request we will provide you a copy of the data to the extent required by law.
    • Right to rectification: you have the right to rectification of your data, wherever such data is incorrect or incomplete.
    • Right to erasure: you have a right to erasure regarding data that is no longer required for the original purposes or that is processed unlawfully.
    • Right to restriction of processing: upon your request, we will restrict processing of personal data according to Art. 18, wherever there are uncertainties regarding our right to process such data or while a decision regarding your objection to such processing is pending. In such cases we will only retain data, restrict any processing to the minimal extent necessary
    • Right to object: if you consider that we are misusing your personal data, you have the right to make a complaint to the Information Commissioner’s Office, and the right to seek to enforce your rights through judicial remedy. 
  • Right to withdraw consent: wherever you gave consent to a data processing, you have the right to withdraw your consent to us at any time. As a result, we will not continue processing data based on this consent in the future. The withdrawal of consent does not affect the legality of the processing carried out based on the consent until the withdrawal.

 

How we use information about you

Under data protection law, we can only use your personal data if we have a proper reason, eg:

  •           where you have given consent
  •           to comply with our legal and regulatory obligations
  •           for the performance of a contract with you or to take steps at your request before entering into a contract, or
  •           for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

We collect information about you to tailor and manage the Services. If you consent, we will email you about news, updates, and other products and services we think may be of use to you. The lawful basis for this processing is consent. We may use your information to provide you with targeted content, information and offers. 

 

We will always treat your personal data with the utmost respect and never sell or share it with other organisations outside for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

 

Marketing and Communication

We would like to send you news, updates and information about our products and services which may be of interest to you. If you have consented to receive such marketing, you may opt out at a later date.

You have a right at any time to stop us from contacting you for marketing purposes. You can do this by unsubscribing using the link at the footer of any email we send you. Alternatively, if you no longer wish to be contacted for marketing purposes, and/or you would like your data to be removed permanently, please contact us at [email protected] or by post at the above address.

In our newsletters we use commercially established technologies, enabling us to measure interactions with the newsletters (such as opening of the email, clicked links). We use this data for general statistical evaluations as well as for the optimisation and further development of our content and communications. This data is collected using small graphics embedded in the newsletter (pixels), which can also collect technical data regarding the device you use to open and view the email. The legal basis for this is our legitimate interest. Through our newsletter we want to share content that is as relevant as possible for you, and better understand what you are actually interested in. If you do not wish for the analysis of usage behaviour, you can unsubscribe from our newsletter or deactivate graphics in your email program by default. 

Access to your information and correction

You have the right to request a copy of the information we hold about you. If you would like a copy of some or all of your personal information, please [email protected]  or write to us at the above address.

We want to make sure that your personal information is accurate and up to date. You can correct the information we hold on you by clicking “update preferences” in the footer of any marketing email we send to you, or by emailing us at [email protected]  or writing to us at the above address.

Cookies

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and compile statistical reports on website activity. We may also use this information for the purposes of targeting marketing messages on third party platforms including Facebook, Twitter, and Google.

For further information, visit www.aboutcookies.org or www.allaboutcookies.org.

 

We will ask for your consent to place cookies or other similar technologies on your device.  You can set your browser not to accept cookies and the above website explain how to remove cookies from your browser. However please note that in some cases, some website features may not function without cookies switched on.

 

Third parties

In collecting, processing and storing your data, we may use the following data processors, which are bound by Data Processing Agreements to ensure compliance with data protection rules.

  • Google
  • Meta
  • OpenStage

Disclosure of your information to third parties

We may share your information from time to time, as far as it is required in order to collect, process and store your data, with:

 

  • The third parties set out above
  • Any person where necessary:
    • Under any applicable laws or regulations of the UK for any purposes required by such person under those laws or regulations;
    • To enforce or apply our Site’s terms and conditions or other contracts; and/or
    • To protect our, our users’, or any other third party’s rights, property, or safety

Other websites

Our website contains links to other websites, including our store at The Swell Season Store https://store.ARTIST WEBSITE URL (“Store”). The Store is governed by a separate privacy policy accessible through the footer of that site. This privacy policy applies only to [The Swell Season Website] https://www.theswellseason.com. When you click through to other websites, you should be aware of their privacy policies. 

Changes to our privacy policy

We review our privacy policy regularly and we will place any updates here on this page. This privacy policy was last updated on 21 August 2024. 

How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you: 

  • By email: [email protected] 
  • By post: c/o The Hat Factory, 166-168 Camden Street, London NW1 9PT, United Kingdom