Privacy Policy

We understand that protecting your personal information is important. We are a multi-disciplinary experience company and organise, host, and collaborate with partners, to produce events and experiences (Services). This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our Services to you. In this Privacy Policy we, us or our means Semi-Permanent Pty Limited ABN 56 102 230 446.

This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In addition to Australian laws, individuals located in the European Union (EU) may also have rights under the General Data Protection Regulation 2016/679 (GDPR).

Types of information

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable. Personal information under the GDPR is referred to as personal data and is defined as information relating to an identified or identifiable natural person (individual). 
Sensitive information: is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. Sensitive information under the GDPR is known as ‘special categories of data’.
Throughout this Privacy Policy, where we use the term ‘personal information’ this refers to ‘personal information’ and/or ‘personal data’, as applicable, and where we use the term ‘sensitive information’, this refers to ‘sensitive information’ and/or ‘special categories of data’, as applicable. 

The information we collect

Personal information: The types of personal information we may collect about you include:
- your name;
- your contact details, including email address, mailing address, street address and/or telephone number; 
- your age and/or date of birth;
- your credit card or payment details (through our third party payment processor);
- your preferences and/or opinions;
- details of your occupation and workplace;
- information you provide to us through customer surveys;
- details of events or experiences we have provided to you and/or that you have enquired about, and our response to you;
- your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
- information about your access and use of our Services, including through the use of Internet cookies, your communications with our online Services, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
- additional personal information that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
- any other personal information requested by us and/or provided by you or a third party.
Sensitive information: We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law.

How we collect personal information

We collect personal information in a variety of ways, including:
Directly: We collect personal information which you directly provide to us, including when you register for a ticket, when you attend our events, through the ‘contact us’ form on our website or when you request our assistance via email, our online chat or over the telephone.
Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
From third parties: We collect personal information from third parties, such as where someone purchases a ticket on your behalf (only where they need to provide your details), from our partners that we co-produce events with, and details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Collection and use of personal information

Where we are acting as a controller under the GDPR, we will only process personal information where we can identify a lawful basis to do so. 
In providing our Services, we may collect, hold, use and disclose personal information for the following purposes:
To enable you to access and use our Services, including our website.
- Legitimate interests: We may collect necessary information if you browse or use our website. 
To process your registration, provide you with your tickets and register your attendance at our events and/or experiences.
- Performance of a contract: We use and disclose personal information to process your registration, provide you with your tickets and register your attendance at our events and/or experiences.
To coordinate with third party service providers where your ticket entitles you to a third party service (including any accommodation or restaurant experiences).
- Performance of a contract: We may use and disclose your personal information to third party service providers where your ticket entitles you to a third party service (including any accommodation or restaurant experiences), for the purpose of the provision of that third party service. 
To contact and communicate with you about our Services.
- Performance of a contract: We may use your information to send you information about any events and/or experiences you have registered for.
For internal record keeping, administrative, invoicing and billing purposes.
- Legitimate interests: We may use your information to carry out tasks required to operate our business, such as record keeping. You may object to our use of your personal information on the basis of legitimate interests at any time (see the “Your Privacy Rights” below).
- Performance of a contract: We may use your information to bill you and accept payment so that we can provide the requested services to you.
- Legal obligation: We may use your information to keep records where we have a legal obligation to do so, such as company records and tax records.
For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.
- Legitimate interests: We may use your information to improve our services and for business development purposes. You may object to our use of your personal information on the basis of legitimate interests at any time (see the “Your Privacy Rights” below).
For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.
- We and/or our third-party marketing partners may use the personal information you send to us for marketing purposes, if this is in accordance with your marketing preferences.
- Consent: If you subscribe to marketing materials you consent to us sending you the marketing you subscribe to. You may withdraw your consent at any time.
To run promotions, competitions and/or offer additional benefits to you.
- Consent: If you subscribe to receive information about promotions, competitions or additional benefits we are offering, you consent to us sending such information to you. You may withdraw your consent at any time.
If you have applied for employment with us; to consider your employment application.
- Legitimate interests: If you have applied for employment with us, we may collect your information to consider your employment application.
To comply with our legal obligations or if otherwise required or authorised by law.
- Legal obligation: We may use your information if required or authorised to do so by law.
If we will process your personal information for another purpose, which is incompatible with the original purpose, we will notify you of that purpose and the legal basis for our processing prior to further processing your personal information. 
If we rely on consent and you are under 16 years of age, you warrant and agree that, and we may seek confirmation that, you have your parent or legal guardian’s consent to process your personal information for that specific purpose.

Disclosure of personal information to third parties

Where permitted by applicable laws, we may disclose personal information to:
- our partners that we co-produce events with for the purpose of co-producing those events; 
- third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, couriers, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- third party service providers where your ticket entitles you to a third party service (including any accommodation or restaurant experiences) to enable the provision of those third party services;
- our employees, contractors and/or related entities for internal processing;
- our existing or potential agents or business partners for purposes identified prior to disclosure;
- sponsors or promoters of any promotions or competition we run for purposes identified prior to disclosure;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; 
- third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
Upon written request, we may agree to provide you with a list of the third parties we use to process your personal information.

Overseas disclosure

Where we disclose your personal information to third parties listed above, these third parties may store, transfer or access personal information outside of Australia [, including but not limited to, Australia, Portugal, United Arab Emirates, United Kingdom, United States, New Zealand].
Where the disclosure of your personal information is subject to Australian privacy laws we will only disclose your personal information to countries with laws which protect your personal information in a way which is substantially similar to the Australian Privacy Principles or we will take such steps as are reasonable in the circumstances to protect your personal information in accordance with the Australian Privacy Principles.
If the GDPR applies, and we disclose your personal information to third parties in countries that do not have the same data protection laws as the country in which you initially provided the information (i) we will perform those transfers using appropriate safeguards in accordance with the requirements of the GDPR; and (ii) we will protect the transferred personal information in accordance with this Privacy Policy.

Your rights and controlling your personal information

You may be entitled to certain privacy rights, as detailed below. If you would like to request any of your rights listed below, please get in touch with us using the details at the bottom of this Privacy Policy and we will consider and act upon your request in accordance with the data protection laws applicable to your request. We aim to respond to all requests within 30 days of the date of receipt of the request.
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. 
Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.
Marketing, restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you.  Please note, in some situations, we may be legally permitted to withhold access to your personal information or charge a reasonable administrative fee.
Correction/Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information.
Objecting to processing: Under the GDPR, you may have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal information.
Restricting processing: Under the GDPR, you may have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.
Erasure and data portability: Under the GDPR, you may have the right to request details of the personal information we hold about you, or to request that we erase the personal information we hold about you, or that we transfer this information to a third party. 
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant privacy authority in the country in which you are based.

Storage, security and retention of your personal information

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
We will only retain your personal information 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 information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information, whether we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see ‘erasure and data portability’ above for further information.
In some circumstances we may anonymise your personal information (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.

Cookies

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online Services and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal information, this information may be linked to the data stored in the cookie.
We provide a cookie pop-up when you use our online Services to obtain your consent to use cookies. If you do not consent to us using any cookies (including essential cookies) or you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy and we will publish the amended Privacy Policy on our website. If we make any material changes to this Privacy Policy, we will notify you by contacting you through the contact details you have provided to us. 
For any questions or notices, please contact our Privacy Officer at:
Semi-Permanent Pty Limited ABN 56 102 230 446
Email: hello@semipermanent.com
Last update: 14 April 2021
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