Data protection

PRIVACY POLICY OF THE CUSTOMER SERVICE REGISTER

Privacy Statement and Processing Activities in accordance with Regulation 2016/679 of the European Parliament and of the Council. Updated 18.8.2026.

1. DATA CONTROLLER

Helsingin Teatterisäätiö / Helsingin Kaupunginteatteri (Y-tunnus 0116521-0)
Ensi Linja 2
00530 Helsinki

Hereinafter, the controller is sometimes referred to as ‘HKT’

2. CONTACT PERSON IN A MATTER CONCERNING THE REGISTER

Olli Eljaala
Phone +358 50 379 9648
Email olli.eljaala@hkt.fi

3. NAME OF THE REGISTER

Helsinki City Theatre’s customer service register

4. GROUNDS FOR KEEPING THE REGISTER

The register contains personal data on visitors, participants, past, current and potential customers of HKT, as well as representatives of HKT’s personnel, stakeholders and partners.

As a rule, the processing of personal data is based on an agreement between the customer and HKT (e.g. ticket purchase or loyal customer relationship) and HKT’s legitimate interest. We only process your data on the basis of consent when we have asked for separate permission (e.g. electronic direct marketing or cookies).

We process your personal data on the basis of a legal obligation for the following purposes:

• compliance with the obligations laid down in the Act, such as the Accounting Act (1336/1997). This includes, among other things, the processing of customers’ payment data as part of HKT’s financial management and reporting to the authorities.

We process your personal data in order to fulfil our obligations under a contract between us, or to take pre-contractual measures at the request of the data subject, e.g. in the following situations:

• Provision of services, such as the provision of event, facility, meeting and catering services, as well as measures related to the management of these. This includes, for example, the processing of the customer’s contact information and ticket information in order to ensure access to the performance in accordance with the agreement and to inform of any changes.
• Fulfilment and management of contractual obligations and rights related to the customer relationship and loyalty program. Management includes, for example, offering benefits to registered members and communicating with them about the loyalty program.
• Processing requests for quotations and other inquiries related to, for example, upcoming events, renting premises or the terms and conditions of the customer relationship programme before entering into a possible contract.
• Billing, including managing due dates and reminders for contract-based payments.

In certain contexts of processing, HKT has, in accordance with the instructions of the Office of the Data Protection Ombudsman, assessed the use of legitimate interest as a legal basis by means of balancing tests:

• With regard to the customer data register of the ticket sales system, HKT and our partners process personal data on the basis of legitimate interest in the contexts in which personal data is processed for the implementation of customer communications and the development of HKT’s operations.
• In the sub-registers related to website visits, the processing of personal data, such as IP addresses, is based on legitimate interest in the contexts when personal data is processed in order to prevent misuse and fraud, to ensure the functionality and information security of information systems, and to develop HKT’s operations, for example, in the production of statistical data.
• With regard to the subscriber registers of the media release and event invitation systems, the processing of personal data is based on legitimate interest in contexts where the processing is related to the development of HKT’s operations and the provision of information about HKT’s operations.

The development of HKT’s operations is based on the purposes set out in the rules of the Helsinki Theatre Foundation and our legitimate interest in maintaining and improving our theatre services.

5. PURPOSE OF PROCESSING PERSONAL DATA AND THE PURPOSE OF THE REGISTER

The purpose of the register is to develop HKT’s operations, process customer service requests, deliver products and services ordered by customers, and manage customer relationships. The data is used for statistical purposes and to produce more personalised, targeted content in our online services and marketing campaigns. Personal data is processed within the limits permitted and required by data protection legislation.

The register consists of the following sub-registers, among others:

Sub-registers based on order, booking, participation, membership or purchase:

• Customer information and reservation registers of the ticket sales system
• Subscriber registers of the newsletter system
• Registers of the loyalty program (“loyalty club”)
• Event invitation system subscriber registers
• Subscriber registers of the media release system
• Joint registers of social media platforms, including registers of participants and winners of competitions
• Event registration lists, incl. audience outreach registers
• Registers of customer surveys and surveys

Sub-registers based on site visits:

• Cookie Consent Platform Registers
• Web traffic monitoring and analytics systems, including Google Analytics (Google Privacy Policy)
• Customer service chat system
• Website publishing systems, including viewer comment databases and log files
• Digital marketing systems incl. remarketing lists

Sub-registers based on electronic communication:

• Email systems, including customer service forms, contact requests and service messages

The data in the register is used in HKT’s own operations to send tickets, electronic communications, event information, reservation information and customer mailings, as well as to process customer service requests, for example, at the ticket office, customer service chat, instant messaging services, by phone or email. The information in the register can be used to pay compensation for a cancelled performance. HKT uses partners to maintain the customer and service relationship and to carry out the technical supervision and maintenance of information systems. Some of the register data may be transferred to the partner’s servers due to technical requirements.

6. DATA CONTENT OF THE REGISTER

The customer service register and its sub-registers contain, among other things, the following information:

• Person’s first and last name
• Gender
• Date of birth
• Person’s nickname or username
• Contact information and VAT number of the organisation that the person represents
• Email address
• Postal address
• Phone number
• Information about reserved and/or purchased products
• Information about mailing list memberships and non-mailing
• Information on consent to the processing of personal data
• Booking number
• Customer ID
• A person’s feedback text, reply, viewer comment, question, message, or service request
• About health status
• Bank details
• IP address
• IT index numbers and hashes
• Information about the browser and operating system
• Information about the use of the browser during the session
• Information about URLs
• Recording time and log data

7. REGULAR SOURCES OF INFORMATION IN THE CUSTOMER SERVICE REGISTER

Information about the customer is regularly obtained:

• From the customer directly in the system, by email, phone, form or other similar means
• Entered by a data processor or in connection with an automated batch data transfer or other similar automatic update by HKT’s partner (see section 9)
• Through the use of cookies or other similar technologies

8. DATA RETENTION PERIOD

We only store your data for as long as is necessary to fulfil the purposes set out in section 5 above in accordance with the legislation in force at the time.

You can read more about the practices for storing personal data stored in the customer data register of the ticket sales system in our ticket agent partner’s own privacy statement.

We will retain your personal data that you have provided to us in connection with the purchase of a ticket, booking or participation in an event for a maximum period of 10 years in order to comply with our financial and legal obligations. This is based on, among other things, the requirements laid down in the Accounting Act and the Debt Limitation Act, according to which we must retain accounting material and prepare for possible contractual and tort claims.

Joining the loyalty program constitutes a separate contractual relationship, based on which we store the personal data required by the program until the customer relationship ends.

However, you have the right to request that your data be erased (see section 15). Please note that we cannot delete the personal data processed during your customer relationship to the extent that it is necessary to maintain the customer relationship or fulfil our contractual obligations.

The contact information of event participants stored in the event management system will be anonymised no later than one year after the end of the event, and other personal data will be anonymised no later than seven days after the end of the event.

In sub-registers related to website visits, log data is pseudonymised or anonymised either immediately in connection with the recording of the log data or no later than 60 days after the log transaction, unless otherwise required for the investigation of possible misuses, the creation of statistical summary reports or the technical implementation of an individual service.

9. PROCESSORS OF PERSONAL DATA

We use partners such as technical service providers, many of whom also act as processors of personal data. The right to use the register requires access rights to HKT’s or its partner’s information systems and passwords. Within HKT’s organisation, access rights to the register are limited to persons whose work tasks require the use of the data in the register.

Our partners often use third parties, i.e. sub-processors, who help us provide our services and process personal data. We ensure that all subprocessors and processors we use are committed to complying with the requirements of the EU General Data Protection Regulation (GDPR). In many cases, the Subprocessor or Processor’s Data Processing Agreement (DPA) is integrated into their Terms of Service, which we accept when using the Service.

Below is a list of our key processors and sub-processors. Changes to this list will be updated on this page.

(*) means that we are dealing with a sub-processor who has been engaged by one of our processors to carry out certain processing activities on our behalf. Please note that in some cases, the same party may also act as an independent processor for other processing activities.

10. TRANSFER OF DATA OUTSIDE THE EU OR THE EUROPEAN ECONOMIC AREA

Personal data will be transferred outside the European Union if this is necessary to ensure the technical implementation of HKT or its partner (see section 9). When data is transferred outside the European Union, we ensure an adequate level of protection of personal data as required by law.

11. REGULAR DISCLOSURE OF DATA

The information in the customer service register is only available to HKT, except when HKT uses an external partner (see section 9) to provide the service. HKT uses Lippupiste Oy as a partner in ticket sales. To the extent that the data obtained through ticket sales is stored in Lippupiste Ltd’s own customer register and it processes the data for its own commercial purposes, Lippupiste Ltd acts as an independent controller. You can find more information about Lippupiste Ltd’s data processing in their own privacy policy. If we merge or otherwise restructure our operations, the customer’s personal data may be disclosed within the new organization.

12. AUTOMATED DECISION-MAKING AND PROFILING

We do not make automated decisions in accordance with Article 22 of the GDPR that would have legal or similar significant effects on you. However, we may use profiling to target marketing (e.g. based on purchase history or website behaviour) in order to provide you with more interesting content. In addition, our website’s security systems may automatically analyze network traffic and IP addresses to prevent abuse.

13. COOKIES AND BROWSING TRACKING

We may collect information about the user’s terminal device through cookies and other similar technologies, such as the browser’s local data storage. A cookie is a small text file that the browser saves on the user’s device. Cookies often contain an anonymous, unique identifier that allows us to identify and count the browsers that visit our site. Some functional cookies are necessary for our services to function. Therefore, they do not require the user’s consent.

Third parties may place cookies on the user’s terminal device when the user visits our services in order to compile statistics on the number of visitors to different websites or to implement functionalities such as customer service chat. Third parties refer to parties outside HKT, such as providers of measurement and monitoring services. Some third-party cookies are non-essential.

You can find detailed information about the cookies used on this website on our Cookie Policy page.

Our site uses caching to load pages faster and improve your user experience. The cache creates temporary copies of website content, such as images, scripts, and user session data, so that your browser can display them more quickly on subsequent visits. This includes using the browser’s local cache as temporary storage. Once you have made your consent choices through our consent management platform, our website will adjust its behaviour accordingly. In addition, we use an external distributed content delivery network (CDN) to serve static content, such as images.

Our services may also contain links to other sites and social networks, but we are not responsible for the privacy practices or content of these third-party sites. We recommend that you review the privacy terms of these services.

14. LOCATION INFORMATION

The location data of the user’s terminal device may be used to provide location-based services, such as providing regional content and displaying targeted advertising, provided that the user has given their explicit consent to the use of location data or if the location data has been made anonymous.

Location information is determined using available positioning methods, such as GPS and the locations of Wi-Fi hotspots and cellular access points. The user can withdraw their consent at any time in the settings of the terminal device and application.

15. RIGHTS OF THE DATA SUBJECT

We are committed to providing our users with choices and controls regarding their privacy. Below, we list the different ways in which our users can influence the collection and processing of data.

Right of access to and rectification of data

The data subject has the right to check what information about him or her has been stored in the register. You can submit a request for inspection by email to info@hkt.fi or by post to:

Helsingin Kaupunginteatteri / Tietosuoja
Ensi Linja 2
00530 Helsinki

Please be prepared to prove your identity when requesting so that we can ensure the security of your information.

The inspection request can also be submitted in person at Ensi Linja 2 / 00530 Helsinki.

The data subject has the right to demand the correction of incorrect data by notifying the data by e-mail info@hkt.fi or by post to the above address.

Right to object to electronic communications

The data subject has the right to prohibit electronic marketing communications via the link at the end of each message or by notifying them by e-mail info@hkt.fi

Blocking and clearing cookies

The user has the option to block the use of all cookies by changing the settings of their browser. Non-necessary cookies, such as those related to website analytics, can be blocked by modifying the settings below. Disabling the use of cookies may affect the functionality of our services and/or prevent the use of some of our services, such as the visibility of videos embedded on the website.

The user can clear cookies in the browser settings. By clearing cookies at regular intervals, the user changes the identifier, which is used to create a profile of the user. However, clearing cookies does not completely stop data collection, but rather resets the profile based on previous behavioral data.

Consent to the use of location data

The user can give their consent to the use of location data in the settings of the terminal device and the application. The settings also allow the user to withdraw their consent at any time.

Right to erasure

The data subject has the right to request the controller to delete their data from the systems (the “right to be forgotten”) by notifying them by e-mail info@hkt.fi or by post to the above address.

Right to data portability

The data subject has the right to demand that the controller transfer their data to another system in a commonly used transfer format. The right only applies to information that the data subject has provided to the controller. Requests for data portability should be notified by email info@hkt.fi or by post to the address above.

Right to object to automated decision-making and profiling

The data subject has the right to object to profiling carried out for the purpose of direct marketing by notifying the data by e-mail info@hkt.fi or by post to the above address.

Right to lodge a complaint with a supervisory authority

If you consider that the processing of your personal data violates data protection legislation, you have the right to lodge a complaint with the Data Protection Ombudsman (www.tietosuoja.fi).

16. PRINCIPLES OF REGISTER PROTECTION

Manual materials concerning the register are stored in protected facilities. The data stored and processed digitally is stored in databases that are protected by firewalls, passwords and other technical means. The databases are located in facilities that are monitored around the clock. Within HKT’s organisation, access rights to the register are limited to persons whose work tasks require the use of the data in the register.

17. CHANGES TO THE PRIVACY POLICY

We are constantly developing our services and reserve the right to change this privacy policy by announcing it in our services. The changes may also be based on changes in legislation. We recommend that you review the content of the privacy policy regularly. The current version of this Privacy Policy can be found at the URL https://hkt.fi/kayttoehdot

CAMERA SURVEILLANCE PRIVACY POLICY

1. DATA CONTROLLER

Helsinki Theatre Foundation Sr / Helsinki City Theatre (Business ID 0116521-0)
First Line 2
00530, Helsinki
Hereinafter, the controller is sometimes referred to as ‘HKT’.

2. PERSON RESPONSIBLE FOR REGISTER MATTERS

Name: Eemil Hallikas, Technical Property Manager
Phone: +358 50 3424 200
Email: eemil.hallikas@hkt.fi

3. NAME OF THE REGISTER

Helsinki City Theatre’s recording camera surveillance systems

4. RIGHTS TO THE REGISTER

Person responsible for the register and persons authorised by him or her

5. PURPOSE OF USE OF THE REGISTER AND GROUNDS FOR PROCESSING

The primary goal of camera surveillance is to prevent crime and vandalism. The aim is also to improve the safety of customers and staff and to protect the assets held by the company. The register data is used to investigate criminal and accidental events and, if necessary, to identify people who have moved around the premises.

6. DATA CONTENT OF THE REGISTER

The register contains footage recorded by surveillance cameras. Material is accumulated in digital and analogue formats. Cameras have been placed at the entrances of properties/theatres owned and leased by HKT, in customer areas and in other locations considered technically important. The registers record the persons moving and staying in the areas covered by camera surveillance.

7. REGULAR SOURCES OF INFORMATION

The register consists of analogue or digital recordings transmitted by cameras installed in places deemed necessary by the company. Camera surveillance recording at the site has been announced with stickers and signs indicating this.

8. DATA RETENTION PERIOD

The data is stored for a maximum of 2 weeks, after which the data is destroyed so that the system saves new image data on top of the old image data. The recording may be stored after the deadline if it is necessary to complete the processing of a harassment, harassment, inappropriate behaviour, crime, occupational accident or occupational safety matter that has been investigated before the end of the time limit.

9. PROCESSORS OF PERSONAL DATA

The recordings are treated confidentially. The recordings are processed by HKT’s persons responsible for camera surveillance and our partners for service and maintenance purposes.

10. TRANSFER OF DATA OUTSIDE THE EU OR THE EUROPEAN ECONOMIC AREA

The data in the register will not be disclosed outside the EU or the European Economic Area.

11. REGULAR DISCLOSURE OF DATA

As a rule, the information is not disclosed anywhere. Data may be disclosed to the police or other authorities in cases where a crime has been committed or is suspected of having been committed in which the legal conditions for disclosing data are met.

12. PRINCIPLES OF REGISTER PROTECTION

The data is protected by means of access control and access rights. The register can only be accessed by those persons employed by HKT and our partners for service and maintenance purposes who need the data in their work duties.

13. INFORMING THOSE STORED IN THE REGISTER

Video surveillance is announced on separate signs. The register description is available on request.

14. RIGHTS OF THE DATA SUBJECT

Right of access to and rectification of data

The register contains automatically and technically stored information that, as a rule, does not contain incorrect information. An unnecessary or outdated recording will be automatically deleted within approximately 2 weeks.

The data subject has the right to check what data concerning him or her has been stored in the register. The inspection request must be sent in writing and signed to the following address:

Helsinki City Theatre / Privacy Policy
First Line 2
00530 Helsinki

After making a sufficiently detailed and specific request for access, the person has the right to access the information contained in the recordings concerning him or her, with the rights and restrictions specified in more detail in the General Data Protection Regulation. The response to the inspection request will be sent to the person who submitted the inspection request by post.

Right to lodge a complaint with an authority

We aim to resolve any disputes primarily directly with the data subjects. If the data subject considers that we have not processed the personal data lawfully, the data subject may lodge a complaint with the data protection authority.

15. CHANGES TO THE PRIVACY POLICY

We are constantly developing our services and reserve the right to change this privacy policy by announcing it in our services. The changes may also be based on changes in legislation. The current version of this Privacy Policy can be found at the URL https://hkt.fi/kayttoehdot/

TERMS OF USE OF THE SITE

These terms of use apply to the use of the website (hkt.fi) of the Helsinki Theatre Foundation/Helsinki City Theatre (HKT). The website serves as HKT’s digital service platform, the purpose of which is to provide information about the theatre’s programme and operations and to enable the purchase of tickets. Your use of the Site is subject to acceptance and compliance with these Terms and Conditions.

1. COPYRIGHT AND MEDIA

The content of the website, including texts, images, logos and graphics, is protected by copyright law and international agreements. The copyright of the material belongs to HKT or other information providers. The material on the website may only be used for personal and non-commercial purposes.

Media and press: Images intended for theatre news and publications are available in the Media Bank (works in the programme) and in the Image Bank Archive (works that have been removed from the programme). The images are freely available to the media and content producers for this purpose, provided that the name of the photographer is mentioned in accordance with good practice. The republication, modification or commercial use of other content on the website requires HKT’s prior written consent, which must be requested through the contact information of the media bank.

2. TERMS OF USE AND SECURITY

The website and the functions it offers, such as electronic service forms and feedback channels, must be used in accordance with current legislation and good online practice. Inappropriate use refers to any activity that violates the rights of HKT, its staff or other users, or endangers the security of the service.

You may not:

• Sends inappropriate material: The forms, feedback channels or comment fields on the website may not be used to send or publish material that is unlawful, threatening, defamatory, discriminatory, racist, offensive to morality or otherwise inappropriate.
• Infringe the rights of third parties: You may not submit any material through the Site that infringes another’s copyright, trademark, or privacy rights, impersonate another person or deliberately misrepresent your identity (e.g., fake contact information on forms).
• Compromises information security or the operation of the service: You may not attempt to bypass the site’s protections, scan for system vulnerabilities, or overload the service with automated data collection programs (such as bots and scrapers) or other methods aimed at denial of service.
• Disseminating harmful content: Sending spam, mass transmissions, computer viruses or other malware through the site is strictly prohibited.

Viewer comments and moderation: Selected selections of viewer comments sent to the website will be published at the discretion of the theatre. HKT reserves the right to decide on the comments to be published on the website and to remove the published comments if necessary. Viewer comments always represent the opinions of their authors.

The user is responsible for the information security of their own devices and data connections. HKT reserves the right to block access to the website by a user who violates the terms and conditions, to take appropriate legal action and to report any misconduct to the authorities.

3. SEPARATE TERMS OF SERVICE

Ticket sales and customer programs through the Site are subject to terms and conditions separate from these Terms of Use:

• Ticket sales and cancellations: Ticket purchases and cancellations are subject to Lippupiste Oy’s terms and conditions and HKT’s valid ticket terms and conditions.
• Theatre Club: Membership in the loyalty club and the use of benefits are subject to the club’s own terms and conditions, which are available on the Teatteriin club page.

4. LIMITATION OF LIABILITY AND SERVICE LEVEL

The website and the functions contained therein are provided on an “as is” basis. HKT strives to keep the information on the website up-to-date and error-free, but does not guarantee its completeness or uninterrupted operation of the service.

• Ticket information and pricing: The seat availability presented on the website is automatically retrieved from the ticket sales system of Lippupiste (lippu.fi), which serves as the official and primary source of information. Due to technical data transfer, there may be a momentary delay in the location of the site, which is why fully real-time and official availability is always confirmed in the actual ticket sales service. Due to possible dynamic pricing, the final price of the tickets, delivery fees and optional additional services (e.g. ticket insurance) will not be confirmed until the purchase transaction at the ticket sales service checkout.
• Online forms: The website’s electronic service forms (incl. refund requests, feedback and job applications) are provided to facilitate transactions. HKT shall not be liable for any direct or indirect damages, delays or loss of data caused by technical transmission errors or service interruptions.
• Electronic manuals: The digital programmes that may be broadcast on the website are an additional additional service offered to customers and do not form part of the purchased ticket product. HKT does not guarantee their flawless technical functionality or compatibility with the user’s terminal devices.
• General Limitation of Liability: HKT is not responsible for third-party websites or their contents to which the hkt.fi website is linked. HKT shall not be liable for any direct or consequential damages resulting from website downtime, hardware and software failures, security breaches or force majeure. Limitations of liability shall be applied to the maximum extent permitted by mandatory Finnish legislation.

5. USE OF ARTIFICIAL INTELLIGENCE AND AUTOMATIC TRANSLATIONS

HKT utilises artificial intelligence and automation responsibly in its operations in accordance with HKT’s AI principles. More information on the use of artificial intelligence in theatre can be found on HKT’s artificial intelligence page.

In order to improve the accessibility and international serviceability of the website, machine translations and AI-assisted translation tools may be utilised in the foreign-language versions of the website. Although attention is paid to the quality of translations, HKT cannot guarantee the complete accuracy of translations produced automatically, and there may be linguistic or conceptual inaccuracies. In the event of any interpretation or conflict, the original Finnish text of the website is always the primary and legally binding source of information.

6. MODIFICATION OF TERMS AND APPLICABLE LAW

HKT is constantly developing its online services and reserves the right to change these Terms of Use without prior notice. These Terms of Use and your use of the Site shall be governed by the laws of Finland.

7. CONTACTING US

In the event of any questions or faults regarding this website and its terms of use, please contact us by e-mail at: info@hkt.fi.

RULES OF COMPETITIONS AND LOTTERIES

1. ORGANIZER

Helsinki Theatre Foundation (Helsinki City Theatre, hereinafter referred to as “HKT” or “Organiser”), Ensi linja 2, 00530 Helsinki.

2. ELIGIBILITY

Natural persons who are at least 18 years of age are eligible to participate in competitions and related draws organised in connection with HKT’s marketing campaigns. Surveys are open to natural persons aged 15 years or over. Participation does not require the purchase of HKT’s product or service. Employees of the organizer and their family members are not eligible to participate in competitions or draws.

3. PARTICIPATION

Participation in competitions or draws is done in accordance with the participation instructions given at any given time. A person can only participate in the draw for each promotion once. The contests and sweepstakes are not recommended, sponsored, or administered by any third party (such as social media platforms).

4. PARTICIPATION PERIOD

The entry period for each competition or sweepstakes will be announced separately in connection with the campaign update or entry instructions. Answers, reactions or entries registered after the end of the entry period will not be taken into account in the raffle. The organiser is not responsible for any impediments to participation due to IT or other technical reasons.

5. PRIZES

The prize is a prize defined for each campaign (such as a free ticket package to HKT’s performance or another product prize). The winner will be chosen at random using a computer program or by drawing lots from among the participants.

6. NOTIFICATION TO THE WINNER AND DELIVERY OF THE PRIZE

The Promoter will notify you of the win in person (e.g. via email or private message) and/or in a post on the social media platform. If the winner cannot be reached within a reasonable time, the mailed prize will be returned undelivered due to incorrect contact information, or it turns out that the participant has acted in violation of the rules or the law, a new winner will be selected in their place. As a rule, the prize will be delivered within a week after the winner has been announced.

The organiser has the right to disqualify and remove from the draw any participants who attempt to abuse the participation arrangements or influence the results by inappropriate means.

7. RESPONSIBILITY OF THE ORGANISER

The winner of the prize releases the Organiser from all liability and costs that may arise from participation in the competition or from the receipt and use of the prize. However, this discharge does not limit the statutory rights of the consumer under the Consumer Protection Act.

The organiser’s liability towards the participants is limited to the amount and value of the prize that is the subject of the competition or draw. The winner will be responsible for any other costs associated with the acceptance or implementation of the prize.

The organiser is responsible for paying the statutory lottery tax on the prizes mentioned in these rules. The prize cannot be exchanged for cash or another product. By participating in a competition or draw, the participant agrees to comply with these rules and the Organiser’s decisions concerning them. The organiser reserves the right to change the rules by announcing them on its website.

8. PROCESSING OF PERSONAL DATA AND NAME INFORMATION

Personal data collected in connection with the competition or draw will only be processed for the purpose of carrying out the draw and informing the winner. The data can only be used for direct marketing if the participant has given their separate consent to it (e.g. when joining the Theatre Club or subscribing to HKT’s newsletter). By participating in the competition or draw, the participant grants the Organiser the right to publish the winner’s first name and last name on HKT’s website, social media channels and marketing publications.