ENGLISH NATIONAL OPERA & LONDON COLISEUM LIMITED

1. Our privacy commitment to you

We, English National Opera & London Coliseum Limited, are committed to protecting your privacy whilst providing you with a personalised and valuable experience. We will always process personal information in a lawful and fair manner, and this notice is an important part of our commitment to keeping you fully informed about how we use your information.

We do everything we can to keep your information secure and use it only for the purposes outlined in the Privacy Notice.

We have created this Privacy Notice to give you the answers to privacy issues that may concern you when your personal information is provided to us. We may occasionally change this Privacy Notice so please check it from time to time.

This Privacy Notice supplements other notices and privacy policies that we, either collectively or individually, may provide to you from time to time and is not intended to override them (including by way of example, the ENO Breathe Privacy Notice. It is important that you read this Privacy Notice together with any other privacy notice, notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your personal information.

2. Our details

For the purposes of the Data Protection Act 2018 (and related laws), London Coliseum Limited and English National Opera are joint controllers of the processing of your personal information described in this notice. This means both organisations work together to decide why and how your personal information is processed. It also means that they are jointly responsible to you under law for that processing.

Our details are as follows:

• English National Opera is a registered charitable company limited by guarantee incorporated in England and Wales (company number 00426792), with registered charity number 257210 (ENO). ENO is registered with the ICO under registration number ZB279509.
• London Coliseum Limited is a wholly owned subsidiary company of ENO, registered and incorporated in England and Wales (company number 09184219) (LCL). LCL is registered with the ICO under registration number ZB581524.
• ENO and LCL both have their registered office at London Coliseum, St. Martin’s Lane, London, WC2N 4ES.

3. Our Websites

This Privacy Notice relates to the personal information we collect about you including information we collect through the following websites:

• eno.org; and
• londoncoliseum.org (including shop.londoncoliseum.org).

(together, the Websites).

4. How to contact us

Once you have read this Privacy Notice, if you have any questions on how we protect your privacy or deal with your personal information we can be contacted as follows:

ENO & London Coliseum Limited
Contact:	Data Privacy Manager
Address:	London Coliseum, St. Martin’s Lane, London, WC2N 4ES
Telephone:	020 7836 0111
Email:	privacy@eno.org

 
5. How we collect your information?

This Privacy Notice applies whenever you interact with us, whether by phone, email, post, through our Websites, or in person (including at our box office).

We use this information so that we can build a clear picture of how you use our services. This is so we can provide you with a tailored, streamlined, user-friendly experience whenever you take advantage of our services for any purpose, from booking tickets to seeing one of our exciting productions or simply browsing our Websites.

We collect your personal information in different ways, including:

• Information you provide to us, where you:
  • visit and use our Websites, including where you sign up for an account on our Websites;
  • contact us through our Websites or otherwise engage with interactive features on our Websites;
  • buy tickets online, via telephone or in person at our box office;
  • sign up to our mailing list, or newsletters to receive emails and other communications from us;
  • make a donation to us;
  • enter a competition, promotion or complete a survey;
  • provide feedback to us; or
  • get in touch with us by phone or by post (for example if you send us written applications for membership schemes such as our Access Scheme, ENO Friends, Opera Circle Supporters, or American Friends of ENO.

• Information we collect when you visit our Websites. We use cookies to personalise your experience on our Websites and our web server will automatically record your IP (internet protocol) address and generate a profile of how you use the Websites. It does this by tracking your previous visits and generating a log of how you navigate between pages on our Websites. For more details, please see our Cookie Notices. 

• Information from third parties sources:
  • We may collect your personal information through interactions with our social media accounts.
  • We may occasionally gather your personal information from other third parties such as external organisations that you have given your permission to. We feel it is really important that you understand exactly who these third parties are and when this will happen, so please see What kind of information do we collect? section for more details.
  • Information kept in the public domain (for example on Companies House or in newspapers) will occasionally be collected by us to help us fundraise better. This includes press publications, archives, the electoral role, official company websites, charities, other arts organisations, company, director and shareholder information. This may relate to your interests, prior donations to other organisations and financial position.

ENO is committed to following the code of practice set by the Fundraising Regulator. ENO pays a voluntary levy to the Fundraising Regulator as part of its commitment to fair fundraising practices. For more information, please visit the Fundraising Regulator’s website.

6. What kind of information do we collect?

6.1 Information obtained directly from you

We collect different kinds of information depending on how, where and when it was gathered. We will collect information directly from you which may include your:

• Identity information: which may include your full name and title, job title , and date of birth;
• Contact information: your telephone number, email address, billing address and delivery address;
• Financial information: your bank account details and card payment details (this is when you make a payment to us);
• Profile information: your username and password, where you have one of our memberships or an account with us;
• Transactional information payments to and from you and other details of products (including tickets) and services you have purchased from us, details of donations, and your membership history;
• Usage information: information about how you use our Websites and our services;
• Technical information: your IP address (when you visit our Websites – see our Cookie Notices for more details);
• Preference information: responses to surveys that you choose to participate in, information about interest in the arts, involvement with other arts organisations, details about your visit, your contact details to participate in follow up research and demographic information about you (should you choose to provide this); and
• Marketing and communications information: your preferences in receiving marketing from us and our third parties and your communication preferences.

In addition to the above, in some limited circumstances, we collect special category data about you. This includes:

• Health information (including dietary requirements, allergies, and access requirements) which we require to comply with our legal obligations and for which you consent to us using, when attending an event or production we run;
• Biometric information such as your likeness or voice if we photograph, film or record you – for example, as part of an audience.
• Information about your racial and ethnic origin, which we may use to better understand the people we are reaching and how we can broaden the opportunity to experience our work and promote equality and fairness among both our audience and wider participant communities. We process this special category data based on it being in the substantial public interest to promote equality of opportunity and treatment.

We do not process information about criminal convictions.

6.2 If you fail to provide us with your personal information

Occasionally there will be particular services that enable you to choose not to give us particular details. This is your right, but please remember that choosing to restrict the kind of information you offer us will limit our ability to tailor our services to you individually. This could result, for example, in us being unable to get in touch with you to let you know about an exciting new production that matches your interests or changes to performances.

6.3 Information obtained from third parties

We sometimes receive information from third parties such as other theatre organisations where you have given your consent (see for full details), this may include your full name and title, address, telephone number and/or email address.

If we receive information about you from a third party (for example another organisation or individual) or from a public source, we will, where appropriate, let you know who we received it from within a month of such receipt.

7. What we use your information for?

Any information we collect about you will be used in a proportionate, targeted way. This means we will not gather more information from you than is necessary for the purpose for which it was collected. The way we collect your personal information will determine the purposes we use it for.

7.1 How we use your personal information

Purpose	Type of personal information	Legal basis for processing
Where you sign up to a membership scheme or service, we offer such as the Access Scheme or ENO Engage.	Contact; Identity; Financial; Profile; Technical; Transactional; Usage; Preference; Marketing; Health	Performance of a contract we have with you. Compliance with a legal obligation.
Where you are booking tickets or purchasing products or services from us.	Contact; Identity; Financial; Technical; Transactional	Performance of a contract we have with you
To enable us to fulfil any contractual obligations we may have with you, for example to process payments under the contract of sale that is formed between us when you buy a ticket, or to perform a contract we may have with you for membership or donations.	Contact; Identity; Financial; Technical; Transactional	Performance of a contract we have with you.
As part of an initiative or scheme we run, such as ENO Breathe	Contact; Identity; Health	Consent Performance of a contract we have with you.
For the purposes of equal opportunities monitoring	Special category data	Compliance with a legal obligation.
To provide you with support when you contact our support teams.	Contact; Identity; Technical; Transactional	Performance of a contract we have with you.
To enable us to get in touch with you to send you information about your booking or purchase, for example to send you ticket confirmations via email or to let you know what to expect when you arrive.	Contact; Identity; Financial; Technical; Transactional;	Performance of a contract we have with you.
To prevent fraud (including ticket fraud, and fraud in respect of donations).	Contact; Identity; Financial; Profile; Technical; Transactional; Usage; Preference; Marketing; Health	Compliance with a legal obligation
To ensure health and safety of our guests and an event or production we run.	Identity; Contact; Health	Compliance with a legal obligation and protecting your vital interests
To further ENO’s charitable and fundraising objectives and to give us a better understanding of current and prospective supporters.	Transactional; Preference; Usage Identity	Necessary for our legitimate interests, to raise awareness and funds.
To add you to our mailing list and send you communications (electronically or otherwise, depending on what you have requested) about upcoming productions and events, offers, news, ways you can support us and general matters, including our special mailing lists about particular services we offer, such as, our Under 35s scheme or our Access Scheme.	Contact; Identity;Preference;   Marketing and Communications	Consent
To share your information with  other artistic organisations that you have agreed to.	Contact; Identity	Consent
To invite you to participate in research, or to analyse and improve our fundraising work and services.	Contact; Identity; Preference;	Consent Necessary for our legitimate interest, in order to, for example, improve the services we provide or determine the type of performances staged. Performance of a contract we have with you.
To enable you to partake in a prize draw, competition or complete a survey.	Identity; Contact; Profile; Usage; Marketing and Communications	Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Contact; Identity; Technical;	Performance of a contract we have with you.
To monitor the visitors to and their use of our Websites, by identifying their location and to enable us to record website traffic, block disruptive use, ensure the efficiency of our website, personalise information so that our adverts on other websites are more relevant for you, measure the effectiveness of our campaigns, fulfil administrative purposes such as analysing and improving our services.	Contact; Identity; Financial; Profile; Technical; Transactional; Usage; Preference; Marketing; Health	(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
Profiling our audiences and identify the interests of sub-demographics within our audiences by analysing booking patterns and information in the public domain.	Identity; Transactional; Usage;	Consent
Analysing our services on an ongoing basis in order to improve them by assessing how our audiences react to different marketing strategies, in order to tailor what we offer so that you get the best experience possible.	Identity; Transactional; Usage;	Our legitimate interests, to enable a better understanding of our audience’s needs and customise what we offer you
When we (or someone on our behalf) film, record or photograph a performance and you are part of the audience or you agree to participate in a recording (whether audio-visual or audio only)	Identity; Biometric	Our legitimate interests, where your participation, is incidental to the relevant footage or photograph to enable us to widen our audience through exposure in other media. Consent, where your participation is more than incidental.

 
8. Marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

8.1 Promotional offers from us

We may use your Identity, Contact, Technical, Usage, Profile Data and Marketing and Communications information 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 or purchased products or services from us and you have not opted out of receiving that marketing.

8.2 Third-party marketing

We will get your express opt-in consent before we share your personal information with any third party for marketing purposes. We may, at the point of collecting your information, ask whether you are happy for us to share your personal information with those involved with staging a production at the London Coliseum, so they can contact you about either current or future productions.

8.3 Opting out

You can ask us or third parties to stop sending you marketing messages at any time by:

• following the opt-out links or ‘unsubscribe’ option on any marketing message sent to you;
• updating your contact preferences on your account with us (where applicable);
• emailing, unsubscribe@eno.org or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

If you have asked us not to contact you, we may need to retain your name and contact details to put you on a suppression list (this is a record of people who have withdrawn their consent and ensures we do not get in touch with you if you have chosen to do this).

Please note we will not be able to agree to your request if we need to keep contacting you in order to fulfil a contract with you, for example if you have bought a ticket or agreed that Gift Aid can be claimed.

• How we will contact you

Where you have provided an email address, we will contact you by email or post unless you let us know that you would prefer to be solely contacted by post.

9. Your information and third parties

We will never sell your information to any third party. We will not share your details with other charities, arts organisations, producers or other third parties for marketing purposes except where you have expressly agreed to hear from other organisations.

We may share your personal information with third parties, from time to time, as set out below:

• with other ENO Group companies on a joint controller basis, for the purpose of group administration, the administration of events and activities, marketing and support;
• with trusted third party service providers, acting as processors, who provide IT and administration services, such as Salesforce, Microsoft Azure and Shopify (and providers of related apps). Where we use such trusted third parties, we require them to adhere to appropriate controls to protect personal information;
• with third party agencies who provide advertising and marketing services, acting as processor, such as Survey Monkey;
• with our professional advisers, acting as processor or controller, including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
• with event partners, acting as controller, who provide event security and catering services;
• with third party payment gateway providers, as processor, who process payments;
• with Arts Council England, as controller, where there is a legitimate interest to do so for example, sharing postcode data or survey information;
• with third parties such as the Fundraising Regulator, the Charity Commission, the ICO and HMRC, acting as controller, where it is required by law or regulation;
• with third party fraud prevention agencies, acting as controller; and
• with other third parties, where we have your permission to do so in accordance with this Privacy Notice.

We may share personal information with 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 information in the same way as set out in this Privacy Notice.

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 (acting as processors) 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.

9.1 International transfers

Currently, we do use some tools or third party services which process data outside the United Kingdom (UK) and European Economic Area (EEA) (such as Survey Monkey, which is based in the US). Where we share your personal information with third parties located outside of the UK or EEA we comply with the requirements for international data transfers and always require suppliers to ensure adequate protection for personal data by stipulating this in our contracts with them.

10. Retaining your personal information

We will keep the information you give us only for as long as we need it. This depends on the purpose we are using it for. For financial information, we will not retain this for longer than required to processed your payment(s), for  ticket buying information we will retain this for 10 years from your last contact with us but for donations we may retain this for longer, especially if this relates to a legacy.

Occasionally, we may need to cleanse our database by using official, regulated data hygiene files. Data ‘cleanliness’ is measured by how error-free a database is. This technology will screen our database against national databases and erase or flag incorrect or obsolete data. By doing this, we will be ensuring that we protect and store your data in the way that law requires.

For more information on our retention practices, please contact us as detailed in section 4 (how to contact us).

11. Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including encrypting financial information. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information 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 will do our best to protect your personal information. However, we cannot guarantee the security of your personal information transmitted to our Websites before it reaches us, and any transmission is therefore at your own risk. Once we have received your personal information, we use strict procedures and security features to prevent unauthorised access.

12. Children

Our Websites are not intended for children and other than where we need to process information in relation to children who are attending events (or as part of memberships we offer), where we collect a limited data set, and we ensure we have obtained the appropriate consent from the child’s parent or guardian. We will not knowingly collect any other personal information from persons under the age of 16 and will immediately delete any such data subsequently so determined.

13. Cookies and your use of our Websites

You will have noticed references to our use of cookies throughout this Privacy Notice. We collect anonymous information about how visitors to our Websites use and navigate them using cookies. A cookie is a very small text (.txt) file that logs activity on our website. This involves us obtaining an IP address from an individual (for example to track previous visits) which is used to identify whether you might like to receive further information from us, for example regarding production advertising. They are also used where this is necessary to enforce our terms and conditions, protect our services or other users. Please refer to our Cookie Notices (ENO and London Coliseum) for more information.

London Coliseum Limited operates the site hosted at https://shop.londoncoliseum.org/ but we use a third party, Shopify, to provide the underlying technology and to process any online orders you make with us. Shopify sets the cookies on this site and information about those cookies is detailed in Shopify’s Cookie Policy – please see https://www.shopify.com/uk/legal/cookies. Shopify’s Cookie Policy explains how you may control cookies it and its third parties set.

14. Your rights

Under applicable data protection laws, you have a right to:

• ask for a copy of the personal information we hold about you.
• request that we correct personal information we hold about you.
• make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you have a complaint, we would appreciate the chance to deal with your concerns before you approach the ICO and ask that you contact us in the first instance. request that we delete the personal information we hold about you if: you think that our purposes for processing the personal information no longer apply; or have withdrawn your consent to our using it and your consent was our lawful basis for processing it; where you consider that our legitimate interests in processing your information do not or no longer apply; and if you think we have processed your personal information unlawfully.
• Withdraw your consent at any time, where we are relying on your consent to processing your personal information, for example, you can request that we stop using your personal information for marketing purposes.
• request restriction of how we process your personal information, which allows you to suspend our use of your personal information if you: want to ensure the accuracy of your personal information; want to establish the lawfulness of our use of your data but do not want us to delete it; want us to retain your personal information beyond the point we require it for the purpose we obtained it for; you have requested that we stop processing your personal information whilst our legitimate interests are balanced against your individual interests.
• Request that we transfer your personal information to a third party, in a structured, commonly used, machine readable format.

If you wish to exercise any of the rights set above, please contact us as detailed in section 4 (how to contact us).

You can find more details about how your data is regulated by visiting https://ico.org.uk/for-the-public.

15. Third Party websites

Our Websites 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 may also use social media to advertise our productions and services to you. The type and detail of information that we can use to provide you with relevant ads will vary depending on the settings in your social media company account.

We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.

16. CCTV

In common with many other public attractions, we use CCTV recording equipment in and around our premises for the protection of our staff and visitors. Recordings may be shared with other public venues and with the police for public safety reasons. If you require more information about our use of CCTV, please see our CCTV Privacy Notice or contact us at: privacy@eno.org.

17. Future amendments to this Privacy Notice

We may make changes to this Privacy Notice where we consider it appropriate, for example, to comply with any applicable legislative or regulatory requirements, so please ensure you check this page from time to time. We will always do our best to notify you of any changes by getting in touch via email, if you have provided an email address to us.

December 2023