Visit Greenwich Privacy Policy

Privacy policy

1.  Introduction

The privacy and security of your personal information is extremely important to us. We process your personal data in line with the Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (UK GDPR).

In this policy, whenever you see the words ‘Visit Greenwich’, ‘we’, ‘us’, or ‘our’, it refers to our registered company name of The Royal Borough of Greenwich Destination Management Company.

We are a partnership based, not for profit, Community Interest Company. We promote Greenwich and the surrounding area as a visitor destination for leisure and business.

Visit Greenwich company is strongly committed to safeguarding your privacy.  This Privacy Policy explains our policy for the collection and use of information about you and your transactions with us.
We reserve the right to make changes to this Policy at any time. Your continued use of our products, applications, services and websites that are subject to this Policy will signify your acceptance of any and all changes to this Policy made by us from time to time.
Visit Greenwich company is the data controller in connection with any personal information collected or received by us arising from your use of any of our products, services, applications, websites and customer support communications.

2.  How we use your personal data

In this section we have set out:
•    the general categories of personal data that we may process
•    the purposes for which we may process personal data; and
•    the legal basis for the processing

We will process your personal data in accordance with the [United Kingdom's Data Protection Legislation]. We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our staff. We use leading technologies such as (but not limited to) data encryption, fire walls and server authentication to protect the security of your data. For all Visit Greenwich companies, all of our staff and whenever we hire third parties to provide support services, we will require them to observe our privacy standards and to allow us to audit them for compliance. 

Simpleview is yet to sign off the copy in blue below.
We recognise the need to ensure that personal information gathered via this website remains secure. We use industry standard Secure Server Software (SSL) for your transactions with us to protect against the loss, misuse and alteration of the personal information under our control. It encrypts all of your personal information, including credit card number, name, and address, so that it cannot be read as the information travels over the Internet.

However, you acknowledge that although we exercise adequate care and security there remains a risk that information transmitted over the Internet and stored by computer may be intercepted or accessed by an unauthorised third party.
When personal data is stored on Visit Greenwich’s systems we take every care to ensure the security of your personal data.  Its information systems are adequately and appropriately protected, by the implementation and maintenance of security controls, against threats to the systems. The implemented security controls are appropriate to the measures of risks and the value of assets, and implemented, used and where relevant tested, correctly, through information security compliance (audit) reviews, to ensure that the required level of security is maintained.

2.1 Online Purchases/Bookings

When you book accommodation, buy attraction/event tickets or order items from our online shop, our order form asks you to give us information specific to that order, including your billing address, shipping address, credit card information and email address. The information that you provide is processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. We also use the information to contact you if there is a problem with your order.  The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
All of our transactions automatically take place on a secure server. All of your personal information is encrypted before it is transmitted over the Internet.

2.2 Visitor Profiling and Statistics

When you buy from us online, our system automatically gathers purchase data, and we also record information about purchases made through our telemarketing, mail order and other marketing operations.
We use this information in two ways: We review what kinds of products and services appeal most to our visitors as a group. This statistical information helps us improve our offerings in the same way that other companies change their catalogue based on what sells best. We use information such as the number of purchases visitors make and the categories of goods and services they buy to make offers to them we believe will be of interest. We do not give out any information about you, as an individual, to anyone, except to complete your transactions, or to comply with valid legal process such as a search warrant, subpoena or court order.
The legal basis for this processing is legitimate interest.

2.3 Marketing

We may process information that you provide to us for the purpose of visitor registration, brochure requests, e-newsletters subscriptions and competition entry.  This data may be processed for the purposes of sending you the relevant notifications and media. 
•    E-newsletters: by completing our e-newsletter signup page you are agreeing to receive email marketing communications.  These can be unsubscribed from at any time, simply by clicking the unsubscribe link at the bottom of the email. 
•    Wifi subscription: by signing up for free wifi at Greenwich Tourist Information Centre you are agreeing to receive our email marketing communications, as above.
•    Visitor survey forms both on and offline: by completing our visitor surveys you have the option to opt-in to receiving our communications.
•    Visitor Registration: by completing our Visitor Registration page you are agreeing to register your details to save itineraries and access them again later.
•    Competitions - please check the individual terms and conditions associated with each competition.  By entering our competitions and completing our entry forms you are agreeing for your data to be used to administer the competition.
The legal basis for this processing is consent.

2.4 User Generated Content

2.4.1 Social Media

If you use any of our social network pages or applications or you use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance:
If you click on a ‘like’, ‘+1’ or ‘tweet’ or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you

If you ‘like’, ‘+1’ or similar one of our pages on a social network site, we may receive information about your social network profile, depending on your social network account privacy settings.
For more information and for details about how you can control access to your social network profile, you should view the privacy policy and other guidance available on your social network’s website.

2.4.2 Reviews, comments and content

Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.
The legal basis for processing in 2.4.1 and 2.4.2 is legitimate interest.

2.5 Legal Obligation

In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with regulatory and legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

3.  Providing your personal data to others

We may use other third party service providers to provide certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include billing and fulfilment partners, IT solution providers, data analytics providers who process information on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide customer services.
When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations.
In addition to the specific disclosures of personal data set out in this section, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

4.  International transfers of your personal data

We store your data on our secure servers in the United Kingdom and retain it for a reasonable period or as long as the law requires. However, your data may be transferred to, stored at, and processed at a destination inside or outside the European Economic Area by our partners or service providers. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.

5.  Retaining and deleting personal data

This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
Personal data that we process shall not be kept for longer than is necessary for that purpose or those purposes.
Your personal data will be retained for 10 years following the date you cease to be a client, or longer as required to meet our regulatory obligations.

Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests.

6.  Links to third party sites

Some of our websites may contain links to other third party websites that are not operated by us. While we try to link only to sites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those third party websites. We strongly encourage you to view the privacy and cookie policies displayed on those third party websites to find out how your personal information may be used.

7.  Amendments

We may update this policy from time to time by publishing a new version on our website.
You should check this page occasionally to ensure you are happy with any changes to this policy.
We may notify you of changes to this policy by email or through private messaging system or via our website.

8.  Your Rights

In this Section we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries.  Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

(a)        the right to access;
(b)        the right to rectification;
(c)        the right to erasure;
(d)        the right to restrict processing;
(e)        the right to object to processing;
(f)         the right to data portability;
(g)        the right to complain to a supervisory authority; and
(h)        the right to withdraw consent.

You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to the supply of appropriate evidence of your identity. For this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address.
In practice, you will usually either expressly agree (opt in) in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

9.  Cookies

By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

9.1 About Cookies

A cookie is a simple text file that is stored on a user’s computer (or mobile device) that is created when a user visits a website using a program called a browser (Chrome, Internet Explorer, Firefox or Safari).

A cookie isn't a program itself and doesn't actively do anything on a user's computer. A cookie cannot be used to identify a user personally but they do contribute to improving a user's experience of a website.
A cookie simply allows the website to read the contents of the cookie text file. The text file itself simply contains a unique identifier code, the site name and some digits and numbers.

9.2 Why are Cookies used?

Most websites will use cookies in order to improve the user experience by enabling the website to ‘remember’ the user, either for the duration of the visit or for repeat visits.
Cookies do lots of different jobs, such as:
•    remembering what items a user may have added to a shopping basket or an itinerary as the user moves between pages on a website;
•    saving a user's preferences to allow them to customise a website;
•    measuring what users do on a website to ascertain which parts of a website are popular, how long they spend on a website, how often users return, where they come from etc.

9.3 What Cookies are used by this site?

Cookies are set by this website (first party cookies) but may also be set by other websites (e.g. You Tube) that run content on the website’s pages (third party cookies).
Cookies can be set to remember a visitor for the duration of their visit (session cookies) or to remember a visitor for repeat visits (persistent cookies).

10. Recruitment

In order to comply with our contractual, statutory, and management obligations and responsibilities, we process personal data, including special categories of personal data, from job applicants and employees. Such data can include, but isn’t limited to, information relating to health, racial or ethnic origin, and criminal convictions. Further information is available internally for our employees.
The legal basis for this processing is legal obligation.

11. Volunteers

If you’re a volunteer for Visit Greenwich then we may collect extra information about you. 
We collect your information to manage our volunteering programme, from the moment you enquire to the time you decide to stop volunteering with us. This may include references, criminal records checks, details of emergency contacts and medical conditions etc and our purpose is to adhere to relevant legislation and to manage our arrangement (contract) with you. This is to protect both you and us in areas such as safeguarding or health and safety.
We will use your information to contact you about all aspects of volunteering with us. For example: contacting you about an opportunity you’ve applied for or we think you might be interested in, expense claims you’ve made, shifts you’ve booked and to recognise your contribution. It could also include information about things happening where you volunteer and about your volunteering, including asking for your opinions on your volunteering experience. We may also share this data anonymously with funders to help them monitor how their funding is making a difference.
We will retain your personal data for five years after you last volunteered with us.
The legal basis for this processing is contract and legal obligation.

12. Research and consultation
We carry out research and consultations with our partners, customers, staff and volunteers to get feedback on their experience with us. We use this feedback to improve the experiences that we offer and ensure we know what is relevant and interesting to you.
If you choose to take part in research, we’ll tell you what data we will collect, why and how we’ll use it. This kind of research we conduct is optional and you can choose not to take part. For some of our research we may ask you to provide special categories of personal data (e.g. ethnicity). You don’t have to provide this data and we also provide a ‘prefer not to say’ option. We only use it at an aggregate level for reporting (e.g. equal opportunities monitoring).
We may engage a research agency to support our research. We will always make it clear if another party is involved to ensure you are happy for them to handle your personal data on our behalf.
The legal basis for this processing is consent.

13. Photography

Photography is of great value to our work. We take photos for specific purposes such as appearing on our website, in emails, on our social media channels and in flyers and advertising campaigns.
We do not intend to capture individuals in these photos, however, sometimes it may not be possible to take a photo without someone in the background. The purpose of these photos is not based around you as an individual. Where it is the case that we do want to capture individuals in our photos, we will make it clear to you and where possible will use a permission form to ensure you have been able to speak to us about your photo.

The legal basis for this is legitimate interests.

14. Verifying, updating and amending your personal information

If, at any time, you want to verify, update or amend your personal data or preferences or remove your personal data from our records, please email: info@visitgreenwich.org.uk or write to Visit Greenwich, 1st Floor, Ravensbourne University London, 6 Penrose Way, Greenwich Peninsula, London SE10 0EW.
Verification, updating or amendment of personal data will take place within 28 days of receipt of your request.
Should you feel unsatisfied with our handling of your request, you are entitled to escalate this to the supervisory authority. For the United Kingdom, this is the Information Commissioner’s Office (ICO). Its contact information can be found at https://ico.org.uk/global/contact-us 

15. Notification of changes

We may update this policy at any time without notice. Any changes to this policy will be notified by an announcement on this website. Your continued use of this website, following the posting of changes to this policy, will mean you accept these changes.

16. About Us

The website is owned and operated by Visit Greenwich, the Royal Borough of Greenwich Destination Management Company.
We are registered in England (number 8543882) and our registered office is at 1st floor, Ravensbourne University London, 6 Penrose Way, Greenwich, London SE10 0EW
If you have any questions in relation to this Privacy Policy or how we use your personal data contact us at Visit Greenwich, 1st Floor, Ravensbourne University London, 6 Penrose Way, Greenwich Peninsula, London SE10 0EW. If you prefer to use email, please contact info@visitgreenwich.org.uk

visitgreenwich.org.uk