THE BRITISH TOY AND HOBBY ASSOCIATION PRIVACY NOTICE
How we share personal information within BTHA, with our service providers, regulators, other third parties and outside the EEA
Explaining more about direct marketing
How we protect and store personal information
Legal rights available to help manage your privacy
How you can contact us for more support
Third Party Websites
WHAT PERSONAL INFORMATION WE COLLECT AND WHEN AND WHY WE USE IT
|In this section you can find out more about |
· when we collect personal information
· the types of personal information we collect
· how we use personal information
· the legal basis for using personal information
When we collect information
We collect information about you if you:
- register with or use one of the websites or BTHA applications set out below:
– our main website (btha.co.uk);
– our Toy Fair website (toyfair.co.uk);
– our Make Time 2 Play website (maketime2play.co.uk); or
– our Make Time 2 Play mobile application
(together “BTHA website users“)
- are registered as a BTHA Member
- are a Toy Fair Exhibitor
- are a Toy Fair Visitor
- are a BTHA supplier, partner or engage with us through other offline methods e.g. as a politician, a journalist or a member of the public.
Personal information we collect and use if you are a registered BTHA Member
To become a BTHA Member, you would need to register with us either as an individual or on behalf of your organisation. We will collect certain information about you to complete our membership process. This information will include your name, contact details along with optional contact details for officers within your organisation e.g. your health and safety officer. You will be assigned a username and password for secure access to the members’ area of our websites, which is your personal information and you can later change this information if you wish.
Please note that we collect personal information about you where this is provided by your employer. For example, where a company provides us with information about its health and safety officer. We will collect the name and contact details of the health and safety officer.
We use the BTHA Members’ personal information to enter into an agreement with you (i.e. the membership terms and conditions), manage our business relationship with you, to organise and arrange events, and to provide you with our membership service. For instance, we will send you relevant information, including newsflashes regarding topics we think will be of interest to you or where appropriate, to the relevant officer within your organisation.
Personal information we collect and use if you are a Toy Fair Exhibitor
Where you apply to exhibit your products at a Toy Fair exhibition, we will collect personal information relating to you as an individual, if you are an individual exhibitor. If you are applying on behalf of a company, we will collect personal information about you and your company. Such information will include:
- your name;
- your company name
- if you are a BTHA Member or not;
- your contact information, such as your email address, telephone number, job title;
- invoicing contact information, where this is different from your normal contact information;
- other payment information;
Please note that we collect personal information about you where this is provided by your employer. For example, where a company provides us information about its health and safety officer. We will collect the name and contact details of the health and safety officer.
We require this information in order to enter into an agreement with you (i.e. the exhibition terms and conditions) and provide you with services relevant to Toy Fair Exhibition. For example, we need to put you in contact with our service providers who provide you with your stand option, we would need to liaise with your designated health and safety officer and/or other members within your organisation who will be managing your company’s presence at the exhibition.
Please note that we will share your personal information with our core service provider, Global Experience Specialist (GES) Ltd who provide essential services for the Toy Fair Exhibition. GES is a company registered in England and Wales, (company number 02930892), whose registered office is at Silverstone Drive, Gallagher Business Park, Coventry, CV6 6PA.
We will also provide your information to the following entities who also provide essential services for the exhibition.:
Abraxys Ltd – exhibitor data
Agility Logistics Ltd – exhibitor data
GES Ltd – exhibitor data
Reference Technology Ltd – exhibitor and visitor data
Bastion Ltd – exhibitor and visitor (media) data
We will inform you before providing your personal information to these entities, thereby giving you an opportunity to choose which services you require and which services providers to share your personal information with.
Personal information we collect and use if you are a Toy Fair Visitor
By registering as a visitor for a Toy Fair exhibition, we will collect personal information such as your name, job title, company name, physical mailing address, e-mail address, telephone and fax numbers. We will use these details to send you information, (mostly by email) regarding arrangements for the Toy Fair exhibition and other Toy Fair related issues. Where you have indicated that we contact you with such information, we will use these details to tell you about BTHA information, events, related services and toy industry information.
Personal information we collect and use if you are a BTHA website user
When you use our websites, certain limited information, such as your browser type, your device type (e.g. iPhone or Android etc.), your IP address, your search requests, will be collected automatically using cookies and other technologies. A cookie is a small text file containing small amounts of information which is downloaded to / stored on your computer (or other internet enabled devices, such as a smartphone or tablet) when you visit a website.
Personal information we collect and use if you are a BTHA supplier, partner or engage with us through other offline methods e.g. as a politician, a journalist or a member of the public
If you are a BTHA supplier or business partner, we collect and store your name, contact details and job title in order to manage our business relationship with you.
As part of our communications and public affairs activities, we liaise with Members of Parliament, regulators, trading standard authorities, academic and journalists. Where we liaise with you in such capacity, we will retain your personal information, such as your name and contact details, in order to manage the relationship with you, obtain advice from you as well as share opinions.
Information you provide when you contact us
We collect personal information when you contact us online, by phone or by post in relation to a query or a complaint. This information will include your name, phone number, any personal information in or relevant to the resolution of your enquiry or complaint.
We will use your personal information to answer your queries, handle your complaints and fulfil any requests you make to us.
Legal basis for using your personal information
We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This will be based on at least one of the following conditions:
- we need to use your personal information to perform a contract or take steps to enter into a contract with you. For example, to take payment for the services we provide you as an Exhibitor, in relation to a Toy Fair Exhibition. Some of the information we collect in relation to your Toy Fair application is mandatory (indicated by *), without which, we will be unable to provide you with the service; and/or
- we need to use your personal information for our legitimate interest as a commercial organisation. For example, we will evaluate information on your visits to our websites for analytical purposes to understand how people use our websites, so we can improve them. In all such cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights and you have a right to object to processing as explained in the Legal Rights section below; and/or
- we need to use your personal information to comply with a relevant legal or regulatory obligation that we have. For example, we are required to retain some personal information in order to fulfil our tax obligations.
If you would like to find out more about the legal basis for which we process personal information please [contact us / click here].
SHARING PERSONAL INFORMATION OTHERS
|In this section you can find out more about how we share personal information: |
· within BTHA
· with third parties that help us provide our services
· with government organisations and agencies, law enforcement and regulators
We do not routinely transfer personal information outside the European Economic Area
We share your personal information in the manner and for the purposes described below:
- your personal information will be held on our computers in the UK and will be accessed by our staff as necessary to provide you with our services and to manage our business;
- we will share your personal information with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and to use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include:
- IT service providers who help manage our IT and back office systems or provide us services in relation to our websites or our applications;
- organisation who help with organising or running our events, for example, as previously mentioned, we will transfer the personal information of Toy Fair Exhibitors to Global Experience Specialist (GES) Ltd who provide essential services for the Exhibit; and at your choice, to Abraxys Ltd who provide [include service type]; Reference Technology Ltd who provide [include service type]; and Bastion Ltd who provide [include service type].
- with government organisations and agencies, law enforcement, regulators, which includes the Information Commissioner’s Office, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies. Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before any personal information is disclosed;
- we share in aggregate, statistical form, non‑personal information regarding the visitors to our websites, traffic patterns, and website usage with our partners, affiliates or service providers; and
- if, in the future, we sell or transfer some or all of our business or assets to a third party, we will disclose information to a potential or actual third party purchaser of our business or assets.
Transfers outside the EEA
We do not routinely transfer your information outside the European Economic Area, but where we do so, we will ensure that the information receives the same level of protection by obtaining contractual commitments from our service providers to protect your personal information, such as the EU Commission approved Standard Contractual Clauses. Some of these assurances are well recognised certification schemes like the EU – US Privacy Shield for the protection of personal information transferred from within the EU to the United States.
You have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments) to ensure the adequate protection of your personal information when this is transferred as mentioned above.
EXPLAINING MORE ABOUT DIRECT MARKETING
|In this section you can find out more about: |
· how we use personal information to keep you up to date with our products and services.
· how you can manage your marketing preferences
How we use personal information to keep you up to date with our products and services
We use personal information to let you know about our events and services that we believe will be of interest to you. We will contact you by email or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level;
- only send you communications which we believe will be of interest or relevance to you and at all times in line with your permissions;
- at any time you can update or correct your personal profile either as a BTHA Member or a Toy Fair Exhibitor, or change your preferences for the way in which you would like us to communicate with you, including how you receive details of latest news updates from us. Please note that you will not be able to opt out of updates which are essential to the service we provide e.g. industry related information we provide to BTHA Members or service related information provide to Toy Fair Exhibitors as this is not marketing information. However, where you cease to be a BTHA Member or Toy Fair Exhibitor, we will cease further communication with you upon your request;
- if you have an online account with us, the easiest way to make updates to your marketing preferences and/or change your personal details is to log onto your account. You can also click the “unsubscribe” link that you find on any online newsletters you receive [or] [contact our customer support team by clicking here];
- you can ask us to stop direct marketing at any time ‑ you can ask us to stop sending email marketing, by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively you can contact us at [link]; and
We recommend you routinely review the privacy notices and preference settings that are available to you on any social media platforms as well as your preferences within your account with us.
HOW WE PROTECT AND STORE YOUR INFORMATION
|In this section you can find out more about: |
· the measures we have put in place to secure your personal information
· our policy in relation to children’s personal information
· for how long we store your personal information
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorised disclosure or access to such information appropriate to the nature of the information concerned.
Measures we take include:
- placing confidentiality requirements on BTHA staff and service providers;
- destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected;
- following strict security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and
- using secure communication transmission software (known as “secure sockets layer” or “SSL”) that encrypts all information you input on our website before it is sent to us. SSL is an industry standard encryption protocol and this ensure that the information is reasonably protected against unauthorised interception.
As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.
If you are under 18, you may not use our websites, our services, or provide any information to our websites without involvement of a parent or a guardian. We do not knowingly collect information from, and/or about children without the involvement of a parent or a guardian.
Storing your personal information
In specific circumstances we store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
Please contact us if you have any questions regarding how long we store your personal information.
LEGAL RIGHTS AVAILABLE TO HELP MANAGE YOUR PRIVACY
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information. to learn more about each right you have:
- To access personal information
- To rectify / erase personal information
- To restrict the processing of your personal information
- To transfer your personal information
- To object to the processing of personal information
- To object to how we use your personal information for direct marketing purposes
- To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
- To lodge a complaint with your local supervisory authority
If you wish to access any of the above mentioned rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by . Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.
We will not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Right to access personal information
You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of; (a) the source of your personal information; (b) the purposes, legal basis and methods of processing; (c) the data controller’s identity; and (d) the entities or categories of entities to whom your personal information may be transferred.
Right to rectify or erase personal information
You have a right to request that we rectify inaccurate personal information. We will seek to verify the accuracy of the personal information before rectifying it.
You can also request that we erase your personal information in limited circumstances where:
- it is no longer needed for the purposes for which it was collected; or
- you have withdrawn your consent (where the data processing was based on consent); or
- following a successful right to object (see right to object); or
- it has been processed unlawfully; or
- your personal information must be erased to comply with a legal obligation to which BTHA is subject.
We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
- for compliance with a legal obligation; or
- for the establishment, exercise or defence of legal claims;
Right to restrict the processing of your personal information
You can ask us to restrict your personal information, but only where:
- its accuracy is contested, to allow us to verify its accuracy; or
- the processing is unlawful, but you do not want it erased; or
- it is no longer needed for the purposes for which it was collected, but you still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal information following a request for restriction, where:
- we have your consent; or
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to transfer your personal information
You can ask us to provide your personal information to you in a structured, commonly used, machine‑readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:
- the processing is based on your consent or on the performance of a contract with you; and
- the processing is carried out by automated means.
Right to object to the processing of your personal information
You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Right to object to how we use your personal information for direct marketing purposes
You can request that we change the manner in which we contact you for marketing purposes.
You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.
We may redact data transfer agreements to protect commercial terms.
Right to lodge a complaint with your local supervisory authority
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
- by email: email@example.com
- In writing: BTHA House, 142-144 Long Lane, London, SE1 4BS
To contact your data protection supervisory authority
You have a right to lodge a complaint with your local data protection supervisory authority, which in the UK is the Information Commissioner’s Office, at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
Issue Date of Privacy Notice: 25 May 2018