Privacy Policy

Introduction

We respect your privacy and are committed to protecting your personal data. The purpose of this Privacy Policy is to explain how we will use any personal data we collect about you, the rights you have over any personal data we hold about you, and to tell you about the policies and procedures that we have in place to respect your privacy and keep your personal data secure.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below.

Contents:

1. Important Information and who we Are
2. what data do we collect about you?
3. How is your personal data collected?
4. How do we use your personal data?
5. How do we share your personal data?
6. Where do we transfer your data?
7. How long do we keep your personal data?
8. How do we protect your personal data?
9. What are your legal rights?

1. IMPORTANT INFORMATION AND WHO WE ARE

Purpose of the Privacy Policy

This Privacy Policy applies to you if we collect and use your personal data including where you subscribe to receive any marketing communications from us or our clients; submit job application details; take part in any competitions or surveys whether carried out on our behalf or on behalf of our clients; attend one of our events; purchase tickets to attend one of our events; contact us over the phone, via email or otherwise by using any of our websites or interacting with us on social media; communicate with us as an individual client or prospective individual client (collectively, our “Services”).

This website is not intended for children and we do not knowingly collect data relating to children. Our corporate clients and suppliers are not data subjects and their data is not personal data for the purposes of this Privacy Policy.

It is important that you read this Privacy Policy together with any other privacy 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.

Please be aware that all job applicants will be issued with a separate Candidate Privacy Notice in relation to the data which we hold in connection with the application process. This Privacy Policy does not apply in respect of our processing of personal data in the context of our relationship with our employees who are issued with a separate Employee Privacy Notice.

The Data Controller – Who we are

Under the General Data Protection Regulations (“GDPR”) a “Data Controller” is a natural or legal person, which alone or jointly with others, determines the purposes and means of personal data processing. A “Data Processor” is a natural or legal person which processes personal data, whether or not they are a third party.

Wildkat Group Limited (“Wildkat”, the “Company”, “we” or “us” in this Privacy Policy) is the Data Controller and responsible for your personal data save where we otherwise notify you that we are acting as Data Processer on behalf of one of our clients.

The Company has subsidiaries in Germany, Paris and the United States and may operate other subsidiaries or branch offices from time to time, including subsidiaries outside of the E.U. (together with the Company, the “Group”), which may act as a Data Controller or Data Processer from time to time. Wildkat is the controller and responsible for all websites in the Group.

We may also act as Data Processor on behalf of our clients where our role is to carry out or to administer campaigns and collect or process data on behalf of our clients (for example, surveys, marketing sign ups and competitions).

Our contact details

If you have any comments or questions about this Privacy Policy or our data processing practices, please address them to us at london@wildkatpr.com or address the letter for the attention of our Data Protection Manager, who can be contacted at:-

Wildkat Group Limited,
Second Floor,
26 Bloomsbury Street,
London,
WC1B 3QJ

Your details and any changes

We need to ensure that the data that we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.

Third Party Links

We sometimes provide you with links to other websites or mobile applications, but these websites and mobile applications are not under our control. We are only responsible for the privacy practices and security of our Services. We are not responsible for the privacy policies, content or security of any linked websites or mobile applications. We recommend that you check the privacy and security policies of each and every website and mobile application that you visit.

In some instances, a third party may operate or host a competition on our website or mobile application, and collect your personal data. In those cases, where we are not the operator or host of the competition, we have no control over the personal data collected and accordingly urge you to review the third party’s privacy policy before participating.

Third Party Campaigns – Data Processing

From time to time we may carry out marketing campaigns, promotions, surveys, competitions and data collection initiatives (collectively “Campaigns”) on behalf of our clients. In some of these instances, we act only as the Data Processor on the predefined instructions of our client, the Data Controller. Where we act as Data Processor we shall abide by the contractual terms that Data Processors and Data Controllers are required to include in their contracts under the GDPR and with other requirements of the GDPR which relate to Data Processors, including, without limitation:-

• Restrictions on engaging sub-processors;
• Requirements to implement appropriate technical and organisational measures to ensure a level of security of personal data appropriate to the risk;
• Requirements to ensure that we can detect and report data breaches in a timely manner to the Data Controller.

We urge you to review the relevant client’s privacy policy before participating in any such Campaign as these will apply in relation to how our client processes your personal data as Data Controller.

2. WHAT DATA DO WE COLLECT ABOUT YOU?

Personal data, or personal information, 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 and surname;
  • date of birth;
  • photographs and videos;
  • signatures;
• Contact Data includes email address, telephone numbers, home address and social media handles;
• Financial Data includes bank details of any suppliers who are individuals;
• Transaction Data: includes:-
  • information about the Services we provide to you (including, for example, what we have provided to you, when and where and, if applicable, how much you paid);
  • any prizes you have won from competitions we have operated;
  • ticket purchases you have made to attend one of our Events;
• Technical Data: includes information about any device you have used to access our Services or our mobile applications such as your device’s make and model, device identifier, operating system, browser, MAC address or IP address, time zone setting and location and other technology on the devices you use to access the Services;
• Profile Data: includes:-
  • your preferences, competition, feedback and survey responses;
• Usage Data: includes information about the pages or sections you have visited on the websites or mobile applications provided by us including the pages or sections you visited, the website or mobile application you were referred from and when you visited or used them, whether you have used a promotion so that the same promotion is not used twice;
• Marketing and Communications Data: includes
  • your preferences in receiving marketing and your communications preferences;
  • information you provide to us with when you contact us by phone, email, post, or when you communicate with us online or via social media;
  • information about electronic communications you receive from us, including whether that communication has been opened and if you have clicked on any links within that communication;
  • answers you provide when you respond to competitions, promotions and surveys (where applicable);
  • your identity, public profile, follows and likes from a social network such as Facebook, Twitter, Instagram, Linked-In (this may include your employment or education information if you include it in your public profile).
• Miscellaneous: other personal data which you may disclose to us when you use our Services at any time or which we may collect about you in the provision of the Services (for example, details of any incident in which you may be involved at one of our events).

From time to time we may also collect and use 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 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 Aggregate 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 notice.

The only Special Category of Personal Data we collect about you is information you provide to us about your health (for example when you are buying tickets for wheelchair accessible spaces at one of our events or as part of the recruitment process to enable us to make reasonable adjustments). We do not collect details about your race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic or biometric data. Nor do we collect any information about criminal convictions and offences, other than those offences committed or allegedly committed at one of our events where it is in our legitimate interests to do so and is in order prevent or detect an unlawful act, where it is necessary in connection with any legal proceedings or prospective legal proceedings, to obtain legal advice, or is otherwise necessary for the purposes of establishing, exercising or defending legal rights.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

Sources of personal data

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

• Direct Interactions: You may give us your Identity, Contact, Profile and Marketing and Communications Data fill in one of our forms, purchase Services from us or by corresponding with us by post, phone, email, social media, online in person or otherwise. This includes personal data you provide when you:-
  • request marketing to be sent to you either by us or by our clients;
  • make enquiries about us providing marketing Services to you;
  • correspond with us in relation to the provision of goods or services to us;
  • buy tickets for one of our events;
  • enter a competition or survey;
  • otherwise subscribe to our Services;
  • give us feedback or otherwise contact us.
• Automated technologies or interactions: As you interact with our website we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.

We may also receive personal data about you from third parties and public sources as set out below.

• Technical Data from analytics providers such as Google based outside of the EEA;

• Identity and Profile Data when you complete one of our surveys from Survey Monkey based outside of the EEA;
• Identity and Contact Data from publicly available sources such as Companies House based inside the EEA;
• Usage Data from email marketing service providers such as Mailchimp based outside of the EEA;
• Identity Data from third party photographers based in the United Kingdom;
• Identity, Contact and Transaction Data from our ticketing agents such as Eventbrite based in the United States;
• Identity, Contact and Profile Data from our clients in connection with their Campaigns;
• Identity, Technical, Profile and Usage Data from Facebook Inc., Twitter, Instagram, Linked In or other social media platforms, where you contact us via social media or consent to them transferring personal data to us when you register for one of our Services using the relevant social media account;
• Identity, Technical, Profile and Usage Data from Facebook Pixel, and/or Google Adwords where we carry out advertisement targeting;
• Identity, Contact, Profile and Marketing and Communications Data from your public profile on social media and networking sites such as Facebook, Twitter, Instagram and Linked In.

We may combine any personal data about you that we receive from you and from third parties.

4. HOW DO WE USE YOUR PERSONAL DATA?

All personal data that we obtain about you will be used in accordance with current data protection law and this Privacy Policy. We, or third party data processors acting on our behalf, will only use your personal data in the following circumstances:-

• As necessary, to perform a contract with you, such as a contract to process an order from you for one or more of our Services including, where applicable, taking payment and carrying out fulfilment and delivery.
• As necessary, to comply with a legal obligation, for the following purposes:

• where you exercise your rights under data protection law and make requests; and
• to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.
• As necessary, for our legitimate interests in providing the Services and ensuring they operate safely, securely and in a commercially suitable way which is tailored to your use and interests.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you vial email or text message or taking a photograph of you at one of our events. You have the right to withdraw consent at any time by contacting london@wildkatpr.com.

With your explicit consent we process personal data about your health to provide you with tailored services such as wheelchair accessible space.

Purposes for which we will use your data

We have set out below, in a table format, a description of the ways we, or our third party processers acting on our behalf, plan to process 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 at london@wildkatpr.com 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/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To send you information which you have requested (e.g. e-shots, corporate brochure) and respond to your enquiries	Identity Contact	Necessary for our legitimate interests (for the effective operation of our business and to provide you with the best service)
To provide you with any of the Services	Identity Contact Transaction	Performance of a contract with you Necessary for our legitimate interests (for the effective operation of our business and to provide you with the best service)
To manage our relationship with suppliers, enable us to pay suppliers and charge, invoice or refund customers (where applicable)	(a) Identity   (b) Contact (c) Financial (d) Transaction	(a) Performance of a contract with you   (b) Necessary for our legitimate interests (keeping financial records for good business governance)
To investigate incidents which take place at our events and complaints	Identity Contact Miscellaneous	Necessary to comply with a legal obligation Necessary for our legitimate interests (to investigate illegal, health and safety and other incidents which have happened at our events, to provide evidence in the event of legal proceedings)
Photographs of attendees at our events	Identity	Necessary for our legitimate interests (to capture footage of events for clients)
To manage our relationship with you which will include:   (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) Providing you with information about our Services (d) Contacting you about administrative matters (e) Managing and responding to any queries or complaints you make or correspondence you send us	(a) Identity   (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you   (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to provide a better service, to correspond with you where you have requested a response and obtain your feedback to improve our services, to resolve any disputes in the early stages to protect our business, to help us to return lost property to its rightful owner).
To verify your online identity for security purposes	Identity Contact Profile	Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to prevent fraud)
To enable you to partake in a prize draw, competition or complete a survey or review	(a) Identity   (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you   (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business, to confirm delivery of a prize, to improve our services)
To notify you of employment opportunities and process recruitment applications	(a) Identity   (b) Contact (c) Profile (d) Marketing and Communications	Necessary for our legitimate interests (to recruit employees)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity   (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)   (b) Necessary to comply with a legal obligation
To deliver relevant marketing communications to you in order to market our Services including, where applicable, processing your registration, creating custom marketing audiences on third party websites such as Facebook and profiling	(a) Identity   (b) Contact (c) Technical (d) Financial (e) Profile	Necessary for our legitimate interests (in order to effectively market our Services and ensure they operate in a commercially suitable way which is tailored to your use and interests)
To deliver relevant website content to you	(a) Identity   (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical   (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity   (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

Promotional offers from us

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.

You may receive marketing communications from us if you requested information from us or purchased goods or services from us.

Third party marketing

We will get your express opt-in consent before we share your personal data with any company outside of the Group for marketing purposes.

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 london@wildkatpr.com.

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.

5. HOW DO WE SHARE YOUR PERSONAL DATA?

We may share your personal data with other companies in the Group.

We will share your personal data with the data processors that help us to provide the Services. These include the following companies and any service provider which replaces them from time to time:-

• External service providers based in the United States who provide our email marketing system, analytics tools; online document storage systems; backup servers; IT hardware; survey tools; social media platforms; and advertisement targeting services;
• Our third party contractors (including venue security) based in the United Kingdom in relation to any incidents in which you may be involved at any of our events in respect of which they may have been involved or have witnessed;
• Professional advisors including lawyers, business affairs consultants, bankers, auditors, I.T., web developers and insurers based in the United Kingdom who provide consultancy, banking, legal, business affairs, insurance, I.T., web development and accounting services;
• HM Revenue and Customers, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances;
• Any externally appointed Data Protection Manager.

We will also disclose your personal data to third parties in the following circumstances:

• with our clients where we are acting as Data Processor;
• if we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
• in order to enforce or apply our Terms of Use or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
• to protect the rights, property, or safety of us, our customers or other persons. This may include exchanging personal data with other organisations for the purposes of fraud protection and credit risk reduction

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.

Save as expressly detailed above in this section, we will never share, sell or rent any of your personal data to any third party without notifying you and/or obtaining your consent.

6. WHERE DO WE TRANSFER YOUR DATA?

Your personal data may be transferred to, and processed in a location outside of the European Economic Area (EEA).

Our subsidiary and many of our external third party processers are based outside of the EEA so their processing of your personal data will involve a transfer outside the EEA.

Some countries outside the EEA do not have laws that protect your privacy rights as extensively as those in the United Kingdom. However, if we do transfer your personal data to other territories, we will put in place appropriate safeguards to ensure that your personal data are properly protected and processed only in accordance with this Privacy Policy. Those safeguards include imposing contractual obligations of adequacy or requiring the recipient to subscribe to or be certified with an ‘international framework’ of protection. You can obtain more information about the safeguards we put in place by contacting us at london@wildkatpr.com.

7. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including 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.

We shall retain the following data for the following periods:-

• We will normally retain your personal data where you sign up for our newsletters or visit one of our websites or communicate with us for as long as you use those Services and for up to two years after your last use of those Services or your last interaction with us (for example, the last time you opened an electronic communication from us or visited one of our websites).
• Where we hold your data as a result of a transaction we will keep basic information including Contact, Identity, Financial and Transaction Data for seven years after we cease transacting with you.
• Where we hold photographs in which you feature we will hold them for archiving purposes.
• Where we act as Data Processor, at the Data Controller’s election we either return or destroy your personal data at the end of the relationship, unless we are legally required to retain it for a longer period.

We will retain your personal data for longer if we believe we may need them in order to respond to any claims, to protect our rights or the rights of a third party, and we will retain your personal data for longer if we are required to retain them in order to comply with applicable laws.

We will always retain your personal data in accordance with data protection law and never retain your personal data for longer than is necessary. If you have any questions about our retention policy contact london@wildkatpr.com.

8. HOW DO WE PROTECT YOUR PERSONAL DATA?

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.

We cannot guarantee the security of your personal data when you transmit it to us. For example, if you email us your personal data, you should be aware that email is not a secure transmission method. As such, you acknowledge and accept that we cannot guarantee the security of your personal data transmitted to us and that any such transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to prevent unauthorised access.

Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

9. WHAT ARE YOUR LEGAL RIGHTS?

You may contact our Data Protection Manager by email at london@wildkatpr.com at any time, to:

• request that we provide you with a copy of the personal data which we hold about you;
• request that we update any of your personal data which are inaccurate or incomplete;
• request that we delete any of your personal data which we are holding;
• request that we restrict the way that we process your personal data;
• request that we provide your personal data to you or a third-party provider of services in a structured, commonly-used and machine-readable format;
• object to us processing personal data based on our legitimate interests; or
• object to us processing your personal data for direct marketing purposes.

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 may refuse to comply with your request in these circumstances.

What we may need from you

Your request must include your name, email address and postal address and we may request proof of your identity. Please allow at least seven working days for us to process your request.

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.

Time limit to respond

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.

Objection to legitimate interest processing

Where you object to processing personal data based on legitimate interests we can continue to process such data if we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or where the processing is taking place for the establishment, exercise or defence of legal claims.

Withdrawing your consent

Where we are processing your personal data based on your consent, you may change your mind and withdraw your consent at any time.

You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email.

You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us at london@wildkatpr.com.

The consequence of you withdrawing consent might be that we cannot do certain things for you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see Cookie Policy.

We use cookies and web beacons on our websites. Third parties also view, edit, or set their own cookies or place web beacons on our websites. Cookies and web beacons allow us and third parties to distinguish you from other users of the website.

The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Privacy Policy, except as required by law

Right to lodge a complaint with a supervisory authority

You may also make a complaint to a supervisory authority for data protection matters. In the UK, this would be the UK Information Commissioner’s Office (https://ico.org.uk/). If you live in another EEA country, you may complain to the supervisory authority in your country. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.

Changes to our Privacy Policy

We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your personal data. We recommend that you consult this page frequently so that you are aware of our latest Privacy Policy and can update your preferences if necessary. Your continued use of our Services shall constitute your acceptance of any revised Privacy Policy.

This Privacy Policy was last updated on 17 October 2019.