1.0 INTRODUCTION

The aim of this Privacy Policy is to inform you about the personal information we, Event Crowd, collect from you when you use our Website (www.theeventcrowd.com), use our products and services, including but not limited to; our courses and when you provide us with your personal data. 

The collection and use of your personal data, and its associated impact on your privacy is protected by Data Protection Legislation. Data Protection Legislation means; the Data Protection Act 2018 (“DPA”) and (i) unless and until the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) is no longer directly applicable in the UK, and any national implementing laws, regulations, and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the DPA and sets out the rules about the collection and use of your personal data . 

By law, we are required to list, how we collect your personal data, why and how we use your personal data and how we protect your personal data, and the rights you have over the personal data we collect from you when accessing our products and services. 

When you provide Event Crowd with your personal data you are agreeing to this  Privacy Policy and you consent to the collection, use and protection of your personal data, as set out within this Privacy Policy. 

1.1 OUR INFORMATION

We are “Event Crowd”, registered in the United Kingdom as “NEXT LEVEL COURSES LIMITED” under the company number 12358026. 

Event Crowd is the data controller, and Event Crowd is registered with the United Kingdom’s Information Commissioner’s Office (The “ICO”) under the registration number ZB192211. 

Our address is: Unit 6, Coy Pond Business Park, Ingworth Road, Poole, Dorset, BH12 1JY, United Kingdom. 

If you have any questions about this Privacy Policy, you can contact us, by post to the above address, or send an email to data@theeventcrowd.com  or call 01202 545 635. Our offices are open during normal business hours 9am-5pm Monday to Thursday and 9am-4pm on Fridays (except English Bank Holidays). 

2.0 HOW WE COLLECT AND USE YOUR DATA

Your personal data  may be collected via our Website (www.theeventcrowd.com); or when you contact us directly, for example, through our sales or customer service department either online or by email or telephone (please note that our calls are recorded for training and monitoring purposes). 

We do not collect, store or make a record of your bank account or credit/debit card details. We use three third-party payment providers Knoma (www.knoma.io)  and Stripe (www. stripe.com/gb) and GoCardless (www.gocardless.com) If you make a one-off payment via Stripe they will hold your bank details as per their privacy policy here www.stripe.com/gb/privacy. If you are making staggered payments for Event Crowd services via our payment partner, Knoma, please note that your bank details may be held by them to collect the agreed Direct Debit payments. Please see Knoma’s privacy policy for more information, this can be accessed here. Or alternatively you may use GoCardless if you are making staggered payments for Event Crowd, please note that your bank details may be held by them to collect the agreed Direct Debit payments. Please see GoCardless’s privacy policy for more information, this can be accessed here  https://gocardless.com/privacy/payers/

2.1 PERSONAL DATA

“Personal data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details held by Stripe, GoCardless and Knoma.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, academic information, preferences, feedback and survey responses.
• Usage Data includes information about how you use the Website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 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.
• We do not normally collect any Special Categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. There may be specific instances where we require additional personal information from you with regard to any disabilities you may have. This information is solely collected for the purpose of providing equal opportunities to all of our students and to mitigate any chances of personal circumstances affecting your studies. We strive to foster and promote equality within our workplace and throughout our student and lecturer community. Under the Equality Act 2010 we entrust that each student has the right to be provided with an equal opportunity within their Event Crowd studies.  The Special Categories of personal data collected is only allowed access by the lead data controller relevant to meeting your needs during your studies with us. This information is not shared internally.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

2.2 DATA WE COLLECT ABOUT YOU FROM YOUR DEVICE

Each time you visit the Website we may automatically collect your personal data relating to details of your Usage Data and journey throughout the Website, this may include the pages you have visited, the time spent on each page, how you viewed the webpage and the links or images you clicked on.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our services, courses and products;
• create an account on our Website;
• subscribe to our services or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our Cookies. Please see our clause on Cookies below.

 2.3 THIRD PARTY INFORMATION

We work closely with the third parties Stripe, GoCardless and Knorma who are based outside the EU, and we may collect, access and analyse data from those third parties. To provide an example, where we offer payment plans via Knorma for Event Crowd services Knorma have authority to share your Financial, Profile, Contact and Transactional Data  with us  for customer and Legitimate Interest purposes. 

We may collect Technical Data from the following third parties:

• analytics providers such as Google (google.co.uk) based outside the EU whose privacy policy is here www.policies.google.com/privacy;
• advertising networks such as Facebook (en-gb.facebook.com) based outside the EU whose privacy policy is here www.en-gb.facebook.com/privacy/policy/ and TikTok (www.tiktok.com) based outside the EU whose privacy policy is here (www.tiktok.com/legal/page/eea/privacy-policy/en);
• search information providers such as Google based outside the EU as listed above.

We may view also view any records about you that are visible within the public domain such as social media accounts based outside the EU and Companies House and the Electoral Register in the UK, based inside the EU.

2.4 COOKIES

2.4.1 “Cookies” are data files that are placed on Your device or computer and often include an anonymous unique identifier. For more information about Cookies, and how to disable Cookies, visit http://www.allaboutcookies.org. 

By using the Website to view our services or to learn more about our company through the online information that we publicly share, a number of Cookies are used by us and third-party providers to collect, view and analyse useful information about our Website visitors to enable the Website to function properly and for user experience to be measured and improved upon. 

Particular Cookies are vital for the stability and functionality of our Website and we do not ask for your consent for these to be used on your internet browser. The Cookies we use, collect data from and analyse are detailed below:

Necessary: These Cookies are absolutely essential for our Website to function properly. These Cookies ensure basic functionalities and security features of our Website, anonymously.

Functional: These are the Cookies that help certain non-essential functionalities on our Website. These functionalities include embedding content like videos or sharing content of the Website on social media platforms.

Performance: These Cookies are used to understand and analyse the key performance indexes of our Website which helps in delivering you a better user experience.

Analytics: These Cookies store information like the number of visitors to our Website, the number of unique visitors, which pages of our Website have been visited, the source of the visit, etc. This data helps us understand and analyse how well our Website performs and where it needs improvement.

Advertisement: These Cookies are used to personalise the advertisements that we show to you so that they are meaningful to you. These Cookies also help us keep track of the efficiency of these ad campaigns.

Other: Other uncategorised Cookies are those that are being analysed and have not been classified into a category as yet.

The information stored in these Cookies may also be used by the third-party ad providers to show you ads on other websites on the browser as well.

2.4.2 COOKIES INFO

We use the following Cookies:

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.

2.5 SUBMITTING YOUR PERSONAL DATA

This section refers to submitting an enquiry, subscribing to our newsletter or filling out a complete a survey, online, over email or over the phone.

2.5.1 When you fill out our forms, we ask for consent of collection, recording and accessing your personal data through your agreement to this Privacy Policy. 

By submitting a query or requesting information, we will respond to you via the personal data you have provided. We may send you follow-up emails to ensure that we have satisfied your reason for enquiring. 

You are able to unsubscribe from our database and request for us to delete a record of your details at any time by emailing data@theeventcrowd.com

2.5.2 What do we do with your personal data?

All the personal data we collect from you is stored within our database that is held within a third-party Customer Relationship Management (CRM) system “Freshworks CRM”. Freshworks CRM stores your data on behalf of Event Crowd and does not have rights to access or share your personal data.  Freshworks privacy policy can be found here: www.freshworks.com/gdpr/company/

By submitting a query or requesting information, we will respond to you via the personal data you have provided. We may send you follow up emails to ensure that we have satisfied your reason for enquiring. 

Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you, such as signing up for one of our courses;
• 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 obligation and enforce our legal rights;
• Send you marketing communications (depending on your preferences);
• Provide customer support to you;
• Analyse how the Service is being used for troubleshooting and improvements;
• Communicate with you; and
• Collect debts, prevent fraud, and protect the integrity of the Service.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

2.5.3 Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table below in Clause 2.6.

2.5.4 External Third Parties

• Service providers acting as data processors based in the UK who provide I.T Rubix Digital based in the UK and system administration services Freshworks who is based in Indian, but CRM is based in Germany.
• Professional advisers acting as data processors or joint data controllers including lawyers, bankers, auditors, accountants, and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as data processors or joint data controllers based in the UK who require reporting of processing activities in certain circumstances.
• Marketing consultants company called XASO based in the UK, who provide marketing services.
• Academic institutes: As an online educational provider with third-party governing bodies to provide accreditation, we may share relevant data with awarding bodies for the purpose of certification. Examples include but are not limited to: The Chartered Institute of Marketing. 
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

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.

2.5.5 International transfers

By using our services or products your personal data may be collected by Google, Facebook, TikTok, GoCardless, Knoma and Stripe, as listed above. This will involve transferring your personal data outside the European Economic Area (EEA) including the United States.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer the personal data to them on the strict conditions that they abide by Article 49 of GDPR and provide similar protection to data shared between UK and the US.

We will ensure that transfers to these servers or any others where required meet all legal requirements of Data Protection Legislation.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

2.5.6 How long do we store you information?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our students and customers (including Contact, Identity, Financial and Transaction Data) for six (6) years after they cease being student and/or customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will 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.

 2.6 Purposes for which we will use your personal data

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. 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.

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

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

2.7 Marketing

 2.7.1 Depending on your preferences, we may send you emails letting you know about new courses, services, products or features, or promotions. You may opt out of these emails at any time in your account settings.

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, purchased our courses, services or products from us and you have opted in to receiving that marketing.

We may use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.

2.7.2 Opting out

You can ask us or third parties to stop sending you marketing messages at any time. You may opt out of email or WhatsApp messaging at any time in your account settings or ticking the relevant boxes to adjust your marketing preferences such as unsubscribing or by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to use of your personal data provided to us as a result of a purchase or of our courses or services or other transactions.

2.8 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, 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.

2.9 YOUR RIGHTS

2.9.1 Under certain circumstances, you have rights under Data Protection Legislation in relation to your personal data, as listed below:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with Legal Obligation or local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a Legitimate Interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

2.9.2 Users from the EEA

Users from the EEA have the rights as listed above and to also opt out of Cookies, access, correct, delete, restrict or object to our use of your personal data.

2.9.3 How to submit a request

If you would like to exercise any of these rights, please submit your request by emailing us at data@theeventcrowd.com

2.9.4 No fee usually required

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 could refuse to comply with your request in these circumstances as governed by the ICO.

2.9.5 What we may need from you

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.

2.9.6 Time limit to respond

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

3.0  COMPLAINTS

For complaints relating to how we process, store or handle your personal data please reach out to us directly within the first instance. We would hope to understand and address any issues you may have and resolve the complaint. 

You do, however, have the right to contact the ICO to discuss the matter. You are able to contact them directly on their website or contact them via the following mobile number 0303 123 1113. 

4.0 UPDATES

Our Privacy Policy is subject to a regular review and where appropriate, we may update and/or change parts of this Privacy Policy. We reserve the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. This Privacy Policy was last updated in January 2023.

5.0 GENERAL

5.1 You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy, at our sole discretion, as set out in this Privacy Policy.

5.2 If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.

5.3 Nothing in this Privacy Policy is intended to, or shall be deemed to, establish any partnership, joint venture or contract of employment between any of the parties.

5.4 Each party confirms it is acting on its own behalf and not for the benefit of any other person.

5.5 Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

5.6 This Privacy Policy is governed by and interpreted according to the laws of England and Wales. All disputes arising under this Privacy Policy are subject to the exclusive jurisdiction of the English courts.