Helsinki Theatre Foundation / Helsinki City Theatre
(Business ID: 0116521-0)
Ensi Linja 2
Hereinafter also referred to as ‘HCT’
2. CONTACT PERSON IN MATTERS RELATING TO THE SYSTEM
Telephone: +358 (0)50 379 9648
3. NAME OF THE SYSTEM
Helsinki City Theatre’s customer information system
4. GROUNDS FOR THE COLLECTION OF PERSONAL DATA
The system contains personal data pertaining to individuals who have visited HCT’s website and/or reserved and/or purchased tickets to HCT’s events and/or signed up for HCT’s digital newsletter and/or interacted with HCT’s customer service and/or taken part in HCT’s marketing campaigns and/or put themselves forward for HCT’s customer focus group and/or attended a focus group. As a rule, HCT only processes personal data with the data subject’s consent. Consent can be given by anyone over 13 years of age. With regard to customers who have purchased tickets and/or subscribed to our services, HCT and its partners have a legitimate interest to process these data subjects’ personal data in order to manage the associated customer accounts.
5. PURPOSE OF PERSONAL DATA PROCESSING AND THE SYSTEM
The system enables HCT to deal with customer service requests, deliver the goods or services purchased by customers and manage customer accounts. With regard to customer focus groups, the objective is to coordinate events and correspond with focus group members. The data held in the system can be used to improve HCT’s operations, for statistical purposes and to produce more personalised, targeted content in our digital channels and marketing campaigns. HCT only processes personal data to the extent permitted and required under the Finnish Personal Data Act.
The data held in the system can be used for HCT’s internal purposes to post tickets, digital newsletters, event information, booking information and customer mailshots as well as to process customer service requests via, for example, HCT’s ticket office, online chat or instant messaging service, telephone or email. The data held in the system can also be used to refund tickets in the event that a performance is cancelled. HCT reserves the right to use partners to manage its customer accounts and coordinate customer relations. Some data from the system may need to be shared with partners for these purposes and uploaded to their servers to satisfy technical requirements.
6. CATEGORIES OF DATA HELD IN THE SYSTEM
Depending on the nature of the customer relationship, the customer information system contains the following categories of personal data:
• First name and surname
• Date of birth
• Profile name
• Contact information and VAT number of the data subject’s organisation (where applicable)
• Email address
• Postal address
• Telephone number
• Information on products reserved and/or purchased by the data subject
• Information on the data subject’s mailing list subscriptions and opt-outs
• Information on the data subject’s consent to the processing of their personal data
• Booking number
• Customer ID
• Feedback, competition entries, spectator comments, questions, messages and/or service requests received from the data subject
• Bank details
• IP address
• IT index numbers and hashes
• Information on the data subject’s browser and operating system
• Information on the data subject’s browser use during a session
• Information on URLs
• Timestamp and log data
7. REGULAR SOURCES OF DATA
The personal data held in the system are generally collected in one of the following ways:
• Customers input the information themselves or provide the information by email or telephone, by filling in a form or by some other comparable means
• The controller or a partner enters the data into the system
• Through cookies or other similar technologies
8. DATA RETENTION PERIOD
HCT only keeps customers’ information for as long as is necessary to achieve the purposes specified above in point 5 and as provided for in the latest applicable laws.
9. PROCESSORS OF PERSONAL DATA
The system can only be accessed with a username and password issued by HCT or its partner or technical service provider. Only employees who need the information held in the system in their work have access privileges.
10. TRANSFER OF DATA TO COUNTRIES OUTSIDE THE EU OR THE EUROPEAN ECONOMIC AREA
HCT reserves the right to transfer personal data to countries outside the European Union if necessary to ensure the technical performance of HCT or its partner. HCT ensures that adequate safeguards complying with the applicable laws are in place whenever personal data are transferred to countries outside the European Union.
11. REGULAR DISCLOSURES OF DATA
The data held in the system are only used by HCT, except where HCT uses an external partner to provide services. HCT’s external ticket sales partner uses personal data for its own purposes in connection with the provision of its services in so far as information collected in the context of ticket sales is entered into the ticket sales partner’s own information system and customer database, and the ticket sales partner has the right to use any personal data collected in this manner for its own commercial purposes. In the event of a merger or other restructuring, HCT reserves the right to share customers’ personal data within the new organisation.
12. AUTOMATED DECISION-MAKING AND PROFILING
HCT reserves the right to use profiling in the context of marketing campaigns and the information security settings on our website.
13. COOKIES AND TRACKING
HCT reserves the right to collect information about users’ devices by means of cookies and other similar technologies, such as the browser’s local storage. Cookies are small blocks of data that the browser places on the user’s device. Cookies often contain an anonymous, unique identifier that allows us to identify and count browsers that visit our site. Some functional cookies are essential for the functioning of our site. These strictly necessary cookies therefore do not require user consent.
Third parties may place cookies on users’ devices when users visit our site to compile statistics on the number of visitors to different sites or to enable features such as our customer service chat. ‘Third parties’ in this context refer to parties not associated with HCT, such as providers of analytics and tracking services. Some third-party cookies are not strictly necessary for the functioning of our site.
Our site may incorporate links to other sites and social media forums, but we cannot be held responsible for the privacy policies or content of these external sites. HCT recommends that users familiarise themselves with the privacy policies of these service providers.
14. LOCATION DATA
HCT reserves the right to use location data from users’ devices to provide location-based services, such as regional content, and to display targeted advertising, provided that the user has given their express consent to the use of location data or if the location data has been anonymised.
Users’ location is determined using tracking technologies such as GPS and Wi-Fi hotspots as well as locations of mobile phone masts. Users can withdraw their consent at any time by changing the settings on their device and application.
15. DATA SUBJECTS’ RIGHTS
HCT is committed to giving its data subjects options and control over their personal data. Below is a list of ways in which our data subjects can influence the collection and processing of their data.
Right of access and right to rectification
Data subjects have the right to check the data that HCT has about them in its system. Requests for access must be in writing, signed and sent to the following address:
Helsinki City Theatre / Privacy Ensi Linja 2 00530 Helsinki FINLAND
Requests for access can also be made in person at Ensi Linja 2, 00530 Helsinki.
Right to opt out of digital communications
Blocking and clearing cookies
Users can block all cookies by changing their browser settings. Non-essential cookies, such as those related to website analytics, can be disabled by changing the settings below. Disabling cookies may affect the functionality of our site and/or prevent the use of some features, such as videos embedded on the site.
Cookie settings and consent
Strictly necessary cookies help to run the site by enabling basic functions such as page navigation and access to secure areas of the site. The site does not function as intended without these cookies.
Functional cookies make it possible to store information that affects the appearance or features of the site. Examples include the user’s language preferences and location.
Analytics cookies help the administrator of the site to understand how users interact with the site by collecting and reporting data.
Advertising cookies are used to track visitors to the site. The idea is to be able to show advertisements that are useful and interesting to specific users and therefore more valuable to the publishers and third-party advertisers.
HCT is currently liaising with providers of certain unclassified cookies in order to classify them.
Users can clear cookies from their browser settings at any time. Regular clearing of cookies changes the identifier that forms the user’s profile. Clearing cookies does not stop the collection of data altogether, however, but rather resets the profile that was formulated based on the user’s previous behaviour.
Consent to the use of location data
Users can consent to the use of their location data in the settings of their device and application. Consent can also be withdrawn at any time by changing the settings.
Right to erasure
Right to data portability
Right to object to automated decision-making and profiling
All hard-copy records relating to the system are kept in a secure space. Digital files are kept on servers that are protected by firewalls, passwords and other technical safeguards. The servers are housed on premises that are under 24-hour security. Only employees who need the information held in the system in their work have access privileges.