Dated: May 8, 2019
Welcome to the The Round Events, Inc.’s privacy notice.
We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
YOUR LEGAL RIGHTS
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how The Round Events, Inc. and our UK parent corporation Silicon Milk Roundabout, Ltd. (collectively “we” or “us”) collect and process your personal data when you use of this website (www.theround.com) and
the services we provide, including any data you may provide through this website.
This website are not intended for children and we do not knowingly collect data relating to anyone under the age of 18. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices we provide and is not intended to replace them.
Our full details are:
Full name of legal entity: The Round Events, Inc.
Email address: email@example.com
Mailing address: 160 Greentree DR., Suite 101, Dover, DE 19904 USA.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the date listed at the top of this page, and previous versions are archived here.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, last name, username or similar identifier.
Contact Data includes email address and telephone numbers.
Technical Data includes internet protocol (IP) address, your login data, browser
type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Media Data includes photos and videos we take and CCTV or other security camera footage at Events.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and arrests.
If you fail to provide personal data where we need to collect personal data under the terms of a contract we have with you, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel the service or agreement you have with us and we will be excused from any required performance.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Profile Data by filling in forms or by corresponding with us by mail, phone, email or otherwise. This includes personal data you provide when you:
create an account on our website;
subscribe to our Services or publications;
request marketing communications to be sent to you;
enter a competition, promotion or survey; or
give us some feedback.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
analytics providers such as Google in the United States and HotJar based inside the EU;
advertising networks such as Facebook, Linkedin based in the United States; and
Public search information and directory providers.
• Contact Data from providers of technical, payment and delivery services such as Stripe, Sendgrid, and Mailchimp based in the United States.
• Identity and Contact Data from data brokers or aggregators such as Linkedin based in the United States.
• Identity and Contact Data from publicly or commercially available sources: Certain third parties make available information, collected both online and offline, such as demographic, information, additional contact information, group affiliations, occupational information, and educational background.
4. How we use your personal data
We will only use your personal data as described in this privacy notice or otherwise as required or permitted by law. Most commonly, we will use your personal data in the following circumstances:
When necessary in order to perform the contract we are about to enter into or have entered into with you, such as to evaluate and respond to your application to Events
To send you marketing communications if you have opted to receive such materials
When you have provided additional consent to use your personal data in a certain manner, such as to participate in a contest, promotion, or survey
When we are required by law to provide or disclose your personal data, such as
in response to a subpoena or search warrant
When we believe that use or disclosure is necessary in emergency situations to
avoid personal injury or property damage to you or others
If we are acquired, merge with another company, or sell substantially all of our
assets to a third party who agrees to comply with applicable legal requirements
When necessary to enforce our rights under our contract with you
• And as further described in the table below.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new user||(a) Identity
|(a) Performance of a contract with you|
|To process and deliver services to you.||
(d) Marketing and Communications
|(a) Performance of a contract with you|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
|To enable you to partake in a prize drawing, competition or to complete a survey||
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about services that may be of interest to you||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established privacy settings where you can view and make certain decisions about your personal data use. You may also opt-out of marketing communications we send you by clicking “Unsubscribe” or otherwise following instructions provided to stop promotional messages. Please note that we may still send you communications related to your applications and use of our Services, but promotional and marketing communications will discontinue in the time period stated for processing your request.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, or by following the opt-out instructions on any marketing message sent to you, or by contacting us anytime by emailing email@example.com.
California Do Not Track Disclosure
5. Please note that we do not recognize or respond to browser-initiated Do Not Track signals or similar mechanisms, as the Internet industry is still working on standards, implementations and solutions and has not yet reached a common understanding of how to interpret or respond to such signals.
Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We have offices in the United States and the United Kingdom. Some of our External Third Parties are based outside of the U.S. operating in the UK or elsewhere in the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the US.
If and when we transfer your personal data out of the U.S., we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain third-party service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us at anytime on firstname.lastname@example.org if you want further information on
the specific mechanism used by us when transferring your personal data.
7. Data security
We have put in place appropriate security measures designed to help prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, or altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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.
If you want further details of retention periods for different aspects of your personal data, please contact us anytime by emailing email@example.com.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances and in certain jurisdictions, you may have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent
Right to prohibit sale of personal information
Right to receive services on equal terms.
If you wish to exercise any of the rights set out above, please contact us anytime by emailing firstname.lastname@example.org.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take
us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and use reasonable efforts to keep you updated.
|Legitimate Interest||means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best experience consistent with our terms of service and privacy notices. You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.|
|Performance of Contract||means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.|
|Complying with a legal or regulatory obligation||means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.|
|Internal Third Parties||means other companies in the Silicon Milkroundabout Ltd Group acting as joint controllers or processors and who are based the US and UK and provide IT and system administration services and undertake leadership reporting.|
|External Third Parties||
means the following categories of parties:
YOUR LEGAL RIGHTS
|Request access||This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This is also commonly known as a “data subject access request”.|
|Request correction||This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.|
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
|Object to processing||
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
You also have the right to object where we are processing your personal data for direct marketing purposes.
In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
|Request restriction of processing||
This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
|Request the transfer||
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
|Withdraw consent at any time||
This applies where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
|Prohibit sale of personal information||California residents have the right, at any time, to direct us not to sell your personal information to third parties.|
|Receive services on equal terms||We are prohibited from denying goods or services, charging a different price, imposing penalties, providing a different level or quality of service, or suggesting that you will receive a different price or rate or different level or quality of goods or services, based on whether you do or do not exercise your rights under California law.|