Effective date: May 24th, 2018
WARNING: Secret Sessions is currently in development. You understand and agree that the Service may still contain software bugs, suffer disruptions and not operate as intended or designated. Your use of the Service at this stage signifies your understanding of and agreement to participate in the Service’s development.
Secret Sessions is an online platform where creatives can become part of a community to promote their content and discover other creative collaborators. Secret Sessions is hosted exclusively in the United Kingdom and is operated from Kent.
Secret Sessions collects different types of information online:
As a company processing your personal data, we are regulated by the General Data Protection Regulation (GDPR). This page is intended to keep you informed about what we do with the personal data we process. ‘Personal data’, for the purposes of the GDPR, means any information from which you can be identified; it includes things like your name, date of birth, e-mail address, delivery address, billing address, telephone number and IP address.
First of all, we’d like to assure you that we are committed to protecting the privacy of all our users. We will endeavour to ensure that the information you provide us with is kept secure and managed within the General Data Protection Regulations.
If you are not happy with any aspect of how we collect and use your data, please let us know so we can try and resolve it for you. Should this not be resolved, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
It is important that the information we hold about you is accurate and up to date. Please let us know if your personal information changes by emailing us at [email protected]
About how you use our site:
We use this information to tailor how our site can help you To fulfill your requirements and deliver what you have asked us for
- To treat you more personally
- To maintain your records
- To send you appropriate marketing communications
- For analysis about how each of our users use the site
1. What information we will collect about you
We collect information about you when you register with us or place an order for products or services. We also collect information when you complete surveys, provide feedback or supply us with information during the course of our relationship. Website usage information is collected using cookies.
We may process certain types of personal data about you as follows:
- Identity Data may include your first name, last name, username, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address, and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type, and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.
2. How We Collect Your Personal Information
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
- order our products or services
- create an account on our site
- subscribe to our service or publications
- request resources or marketing be sent to you
- enter a competition, prize draw, promotion or survey or
- give us feedback
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside the EU;
- advertising networks such as Facebook based outside the EU; and
- search information providers such as Google and BING based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay and PayPal, based inside and outside the EU, and Shopify based outside the EU
- Identity and Contact Data from data brokers or aggregators, for our business-to-business customers only.
3. How We Use Your Personal Information
We will only use your personal data when legally permitted. The most common uses of your personal data are:
- Where we need to perform the contract between us.
- 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 or regulatory obligation.
Purposes for Processing Your Personal Information
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
You will receive marketing communications from us if you have:
(i) requested information from us or purchased goods or services from us; or
(ii) if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
(iii) in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at [email protected] at any time.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
4. Disclosures of Your Personal Information
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
We will not share your details with any other third parties unless we have your explicit consent.
However, if we reasonably believe that we are required by law to disclose your personal information to a third party, whether in compliance with any applicable law or regulation or by court order or in connection with legal proceedings, we may do so. We may also use aggregate anonymised data and share it with third parties.
- 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; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
However, please note that purchasing a ticket for an event outside the European Union, or purchasing goods to be sent to an address outside of the European Union, may require us to transfer your data to third parties outside the European Union, for example to the event venue, for the purpose of fulfilling our obligations under the contract, and you consent to this where purchasing goods or services in the above circumstances.
5. Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for 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.
By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances, we may 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.
6. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at [email protected]
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.
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.
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.
You can choose not to accept cookies and the above websites tell you how to remove cookies from your browser. However, this may prevent our website from functioning properly.
8. Third Party Links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We reserve the right to change this policy at any time. However, we will not change the way we use your personal information without telling you in advance and giving you the chance to opt out of or prevent the new use of your information.
Contacting Secret Sessions
Remember, if you have a privacy concern regarding Secret Sessions you can write to us by email at [email protected]