This policy sets out the basis on which any personal data we collect from you, that you provide to us, or that we may collect from other sources will be processed by us. This includes the various ways in which you interact with us, whether through one of our many websites, for example studylondon.com (“sites”) and our mobile applications, for example, the Visit London mobile application (“apps”). Together our sites and applications are known as our “platforms”. We may also interact with you through the various services we provide, from organising business conferences to administering the domain registration for “dot London” (“services”).

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

You can find a full list of our platforms in Appendix A.

Links to third party sites may appear on our platforms. Those third party sites are not our responsibility, although we use our best efforts to choose them with care. You should read and satisfy yourself with those third parties’ privacy policies before using such linked sites.

1. 1. What information do we collect from you?
      1. Information you give us. This is information about you that you may give us by:
         1. filling in forms on any of our platforms;
         2. as part of using our services;
         3. by corresponding with us by phone, e-mail, online chat or otherwise;
         4. Sharing information on social media from our platforms; or
         5. Reporting a problem or concern with one of our platforms.
      2. Information we collect about you. With regard to each of your visits to our site, we may automatically collect the following information:
         1. technical information, including the internet protocol (IP) address used to connect your computer to the internet, type of mobile device you use, a unique device identifier (for example your device’s IMEI number, the MAC address of the device’s wireless network interface or the mobile phone number used by the device), mobile network information, your mobile operating system, your login information, browser type and version you use, time zone setting, browser plug-in types and versions, operating system and platform;
         2. information about your visit to our platforms, including the full uniform resource locators (URL) clickstream to, through and from our platforms (including date and time); pages you viewed or information you searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
         3. information stored on your mobile device, which may include contact information, friends lists, login information, photos, videos or other digital content, check ins;
         4. details of your use and visits to any of our platforms including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;
         5. we also use GPS technology in some apps to determine your location. Some of our location-enabled services within apps require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by adjusting the settings of the application on your mobile device;
      3. Information we receive from other sources. We may receive information about you if you use any other websites we operate or other services we provide. We also work with third parties (including, for example, electronic analytics, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
      4. We may combine information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
      5. Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, as long as its use is fair and does not adversely impact the rights of the individual concerned. When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair. Our legitimate interests include:
         • Promotion of our purposes, including to develop new offers and services (both independently and with our partners) to promote London to visitors, students and businesses;
         • Administration and operational management, including responding to solicited enquires, providing information that you have requested, research, events management, the administration of our resources and tools.
         • Liaising with third parties, including working with partner organisations to develop new programmes and resources which further our purposes.
      6. If you would like more information on our uses of legitimate interests or to change our use of your personal data in this manner, please get in touch with us using the details in the “Contact us” section below.
      7. We may disclose your personal information to third parties:
         1. in the event that we transfer, sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and/or
         2. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or our safety and/or, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
      8. We may allow our staff, consultants and/or external providers (data processors) acting on our behalf to access and use your information for the purposes for which you have provided to us (e.g. to analyse data and to process payments). We only provide them with the information they need to deliver the relevant service, and ensure that we take steps to ensure that they process personal data in a secure manner.
   2. How do we use your personal information?
      1. We use information held about you in the following ways:
         1. to communicate with you in response to a specific action performed by you on our platforms, e.g. when you book a hotel, buy a ticket, reserve a table, leave a review, enter a competition, etc;
         2. to provide you with support in using our platforms, and to provide you with the information, products and services that you request from us;
         3. to provide you with information about one of our many events, for example our conferences on trade and business in London;
         4. to provide you with information about other services we offer that are similar to those that you have already enquired about, for example newsletters, competitions and offers;
         5. to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing subscriber, we will only contact you by electronic means (e-mail, SMS or WhatsApp) with information about services similar to those which we offer on our platforms. If we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.  If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
         6. to send you news items which are relevant to your interests;
         7. to notify you about changes to our services;
         8. to ensure that content from our platforms is presented in the most effective manner for you and for your computer and/or your mobile device;
         9. to administer our platforms for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
         10. to improve our platforms to ensure that content is presented in the most effective manner for you and for your computer and/or your mobile device;
         11. to help us improve and personalise our services, both on our own platforms and on third party sites;
         12. to allow you to participate in interactive features of our services, when you choose to do so;
         13. as part of our efforts to keep our platforms safe and secure;
         14. to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
         15. to make suggestions and recommendations to you and other users of our platforms about goods or services that may interest you or them;
         16. to comply with applicable laws and regulations, and requests from statutory agencies; and
         17. where it is otherwise necessary for our legitimate interests (or those interests of a third party) and your interests and fundamental rights do not override those interests.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

1. Our Legal Basis for processing data
   1. Organisations that collect and use personal data must have a lawful basis for doing so under data protection law and we are required to let you know the lawful basis on which we rely to process your personal data. We rely upon the following lawful bases:
      • Your consent to use your data for a particular purpose (for example to send you direct marketing by e-mail or to collect sensitive personal data);
      • Where the use of the data is in our “legitimate interests” (see below for more information);
      • Where we need to process your data in order to perform our obligations under a contract that we have entered into with you (for example to enrol you in an event or provide you with access to resources); and
      • To process data where we are under a legal obligation to do so.
2. Will we share your information with others?
   1. We may share your personal information with any member of our group, which includes our group companies both in the UK and outside the UK.
   2. We may share your information with selected third parties including:
      1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
      2. we may (with your consent, where appropriate) pass your details onto third parties including our partners to provide you with information and offers which may be of interest to you;
      3. advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in south London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
      4. analytics and search engine providers that assist us in the improvement and optimisation of our platforms.
3. How do we protect the security of personal data?
   1. We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
   2. While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us.
   3. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
   4. The information we collect from you may be transferred to and processed and/or stored at a destination outside the UK. If we send your personal data outside the UK we will ensure a similar level of protection is afforded to it, by ensuring that we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
4. How long do we keep your data for?
   1. 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
   2. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you no longer have a relationship with us, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.
   3. If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.
5. Your privacy rights
   1. You have a number of rights under data protection legislation. These include:
      1. Right of access

         You have the right to know what information we hold about you and to ask, in writing, to see your records. We will provide you with details of the records we hold as soon as possible and at latest within one month, unless the request is complex. We may require proof of identity before we are able to release the data. Please use the details in the “Contact us” section below if you would like to exercise this right.

      2. Right to be informed

         You have the right to be informed how your personal data will be used. This policy as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.

      3. Right to withdraw consent

         Where we process your data on the basis of your consent (for example, to send you marketing texts or e-mails) you can withdraw that consent at any time. To do this, or to discuss this right further with us, please contact us using the details in the “Contact us” section below.

      4. Right to object

         You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post). To do this, or to discuss this right further with us, please contact us using the details in the “Contact us” section below.

      5. Right to restrict processing

         In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.

      6. Right of erasure

         In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials we will need to keep some limited information in order to ensure that you are not contacted in the future.

      7. Right of rectification

         If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated. To update your records please get in touch with us using the details in the “Contact us” section below.

      8. Right to data portability

         Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.

         Complaints
         If you are unhappy with the way in which we have handled your personal information please contact us using the details below. You are also entitled to make a complaint to the Information Commissioner’s Office – https://ico.org.uk/.

6. How will we let you know of changes to our privacy policy?

   We may update this policy from time to time without notice to you, so please check it regularly. We will however aim to bring any significant changes to your attention. The privacy policy was last updated on 25 June 2022.

7. How to contact us?
   1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to john@johnobriensmusic.com 
   2. Contact Office: 1093 A1A Beach Blvd, S.175 Saint Augustine, Florida
      
      +1 516 695 7098