Policy updated: 19th May 2018
This website is owned and operated by TFNation Ltd (hereafter “TFNation®”, “we” or “us”). Your privacy and wellbeing whilst using our website is extremely important to us - this document explains our commitment to keeping your data safe.
2. Who we are
The law recognises TFNation® as a ‘data controller’. In exchange for this recognition, we are legally obliged to give you some information about who we are.
The specific piece of law which says we have to do this is the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data. It is more commonly known as General Data Protection Regulation (GDPR).
The information we must give you, is as follows;
- Our site address is tfnation.com
- Our company name is TFNation Ltd
- Our registered address is 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
- Our Data Protection Officer is William Michael Edwards and they can be contacted at email@example.com
3. What TFNation® may collect
We may collect and process the following data about you:
- Information you put into forms or surveys on our site at any time.
- A record of any correspondence between us.
- Details of transactions you carry out through our site.
- Details of your visits to our site and the resources you use.
- Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.
5. How does TFNation® use the data collected from you?
We use information about you to:
- Present site content effectively to you.
- Provide information, products and services that you request, or (with your consent) which we think may interest you.
- Carry out our contracts with you.
- Allow you to use our interactive services if you want to.
- Tell you our charges.
- Tell you about other goods and services that might interest you.
If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you (like tickets to our events).
If you are a new customer, you will only be contacted if you agree to it.
If you don't want to be contacted for marketing purposes, please tick the relevant box that you will find on screen.
In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section, you can let us know at any time by contacting us at firstname.lastname@example.org and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible products and services to you.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.
6. Where does TFNation® store your data?
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
We do not store any of your financial details.
If we give you a password, you must keep it confidential. Please don't share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts.
We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct an [annual] review to ascertain whether we need to keep your personal data. Your personal data will be deleted if we no longer need it.
7. How does TFNation® protect your data?
We have invested in a dedicated webhosting system, secure encryption systems and password protection.
All passwords use the PBKDF2 algorithm with a SHA256 hash, a password stretching mechanism recommended by NIST.
We hold a full EV SSL certificate with Comodo CA Ltd, which has certified our website to be authentic and secure.
We hold confirmed payment gateway accounts with Paypal for Business and Stripe. These are utilised to process payments. These gateways are important as they ensure all payments are routed via secure third party systems, meaning TFNation® does not hold any of your financial details.
TFNation® stores a log of successful, partially completed and failed bookings. However, for the avoidance of any doubt, your payment information (being your credit card, debit card or Paypal account details) is not entered into any page hosted by TFNation®. This means TFNation® never receives your financial details an thus can never store them. This is a safety measure we have purposefully put in place to add an extra layer of security in case our site is ever compromised.
Within our staff, only specifically pre-authorised individuals have access to the information provided by our users.
We endeavour to review and upgrade our security and privacy policies as necessary to afford you the maximum level of protection.
8. Disclosing your information
We are allowed to disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer.
- We can disclose it to other businesses in our group.
- We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
- We may contract with third parties to supply services to you on our behalf. These may include payment processing, event software (IT) services, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data.
These are the third parties that have access to your information:
- Paypal - We share your booking reference and type of tickets for itemised billing.
- Stripe - We share your booking reference and email address for billing and payment confirmation.
- JKS Accountants Ltd - For accounting purposes.
- The Hilton Birmingham Metropole - We may share your name and limited identifying details where required to fulfil our contractual obligations along with any allergy or special requirements you have disclosed to us to ease your stay.
- Event Nation Limited (Evena) - Provide website technical support, hosting support, bug fixing and development.
- Our ticket collection desk volunteer team - Our ticket collection team have access to your booking to validate your on-site check-in.
- Mailchimp - If you opt-in to marketing we will share your name and email address with our Mailchimp account whereby Mailchimp will act as a Data Processor for the sending of emails.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
9. Your rights
You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, or by contacting us at any time at email@example.com
Under the GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out in section 12 below.
10. Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
12. Automated Decision-Making and Profiling
In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
The right described in section 11.1 does not apply in the following circumstances:
- the decision is necessary for the entry into, or performance of, a contract between the you and us;
- the decision is authorised by law; or
- you have given you explicit consent.
Where we use your personal data for profiling purposes, the following shall apply:
- Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- Appropriate mathematical or statistical procedures will be used;
- Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
13. Dispute Resolution
If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.
Within 14 days of the appointment of the mediator, the parties will meet with the mediator to agree the procedure to be adopted for the mediation, unless otherwise agreed between the parties and the mediator.
All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.
If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.
This agreement is governed by English, under the exclusive jurisdiction of the English Court.