- our main website (btha.co.uk);
- our Toy Fair site (btha.co.uk/toy-fair/)
- our Make Time 2 Play mobile application;
- the Make Time 2 Play website (maketime2play.co.uk);
- our social media pages on Facebook, Twitter, YouTube and Instagram (although please note that this policy only applies to our use of personal information collected from you on our pages, please refer to the privacy policies of the social media site operators for information about how they and other third parties might use your personal information);
- offline activities which involve the processing of member, supplier or partner personal information.
“Personal information” refers to information which does or is capable of identifying you as an individual.
For the purposes of data protection law, your data controller is the British Toy and Hobby Association Limited (company number: 00388895) of BTHA House, 142-146 Long Lane, London, SE1 4BS.
Please read this policy carefully and re-visit this page from time to time to review any changes that may have been made.
1. What information do we collect from you?
1.1 Browsing: when you use this website, certain limited information (such as your browser type and IP address) will be collected by us automatically. We may also collect information about your usage of this website as you browse our website (see section 6 (Cookies and analytics) below).
1.2 Membership: when you register for membership of the BTHA (either as an individual, or on behalf of an organisation) you will be asked to provide certain information about yourself (including your name and contact details along with optional contact details for officers within your organisation e.g. health and safety officer). You will be assigned a username and password for secure access to the website, which you can later change if you wish – we store this information securely and do not routinely access it.
1.3 Communications with us: we may also collect information about you from messages you post to the website or emails or letters you send to us.
1.5 Social media pages: from time to time, we will organise competitions on our social media pages (including, but not limited to, Facebook, Twitter, Youtube and Instagram). We use the personal information you provide us with (for example, name, email address and postal address) solely for the purposes of administering prizes to competition winners.
1.6 Events: we collect personal information (such as name, contact details, job title) from organisations which attend or exhibit at our events, including the Toy Fair.
1.7 Suppliers: if you are a supplier to a BTHA company, we may collect and store you contact details and job title in order to manage our business relationship with you.
2. What do we use your information for?
The following is an overview of our purposes for using your personal information. Please remember that additional information may be provided to you in a separate notice or contract.
All processing (i.e. use) of your personal information is justified by a “condition” for processing. In addition, processing of sensitive personal information is always justified by a secondary condition. In the majority of cases, processing will be justified on the basis that:
- you have consented to the processing;
- the processing is necessary to perform a contract or take steps to enter into a contract;
- the processing is necessary for us to comply with a relevant legal obligation; or
- the processing is in our legitimate commercial interests, subject to your interests and fundamental rights.
We use your personal information to:
- provide you with access to the members’ area of our website;
- answer your enquiries and fulfil any requests you make to us;
- send member information to you from time to time, including newsflashes regarding topics we think will be of interest to you or where appropriate the relevant officer within your organisation;
- organise competitions and administer prizes;
- organise and arrange events;
- manage a business relationship with you; and/or
- improve our services to you, our websites and our applications by conducting analytics (where appropriate by using anonymised or aggregated datasets)
We do not actively disclose your personal information or make it available to third parties, other than as set out in section 4 (Transfers and disclosure of your information) and in connection with the purposes set out in our disclaimer.
3. How long do we keep your information for?
3.1 We will retain the personal information provided by you for as long as is reasonably necessary for the purposes listed in this policy. However, in some circumstances we may retain personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements.
3.2 In specific circumstances we may also retain 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.
3.3 We apply a general rule of keeping personal information only for as long as required to fulfil the purpose(s) for which it was collected. However, in some circumstances we may retain your personal information for longer periods of time, for instance where we are required to do so in accordance with legal, tax and/or accounting requirements. In all cases, where your information is no longer required we will ensure it is disposed of in a secure manner and, where required by applicable law, we will notify you when such information has been disposed of.
4. Transfers and disclosure of your information
4.1 The information you provide to us will be held on our computers in the UK and may be accessed by or given to our staff or to any member of the BTHA group for the purposes set out in this policy or for other purposes approved by you.
4.2 We may share your information with third party service providers, for example to provide us with IT services in relation to our websites or our applications, or to help with the organising or running of our events. These third parties process your information on our behalf, subject to our documented instructions.
4.3 We do not routinely transfer your information outside of the European Economic Area, but where we do so we will take steps to ensure that the information receives the same level of protection, including by entering into data transfer agreements, such as the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU – US Privacy Shield.
4.4 We may also pass aggregate information on the usage of our site and services onto third parties, but this will not include information that can be used to identify you.
4.5 We reserve the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us. Should any BTHA company be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the business
5. Collection of information by third parties
Our site contains links to other sites whose privacy practices may be different to ours. Please consult the other sites’ privacy policies as we have no control over information that is submitted to, or collected by these third parties. Our social media pages are hosted by third party sites, and the privacy policies of those third parties should be reviewed alongside this policy.
6. Cookies and analytics
6.2.1 where they are essential to make our site work;
6.2.2 to enable us to personalise the content of the site for you;
6.2.3 to compile anonymous, aggregated statistics that allow us to understand how users use our site and to help us improve and monitor the structure of our site. We cannot identify you personally in this way.
6.3 We use both temporary cookies (“session cookies”) and long-term cookies (“persistent cookies”). Session cookies are automatically deleted at the end of each browsing session, whereas persistent cookies are stored in between browsing sessions so that we can remember things about you when you return to our websites and personalise or improve your browsing experience.
6.3 Disabling / enabling cookies
You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our site if cookies are disabled. You can learn more about cookies and how they work at www.allaboutcookies.org or www.youronlinechoices.eu. Visit the “help” section of your browser for how to manage your cookie settings, or follow the links below:
6.5 In addition to cookies, we may use third party web analytics services on our websites or applications, such as those of Google Analytics. The service providers that administer those services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to analyze use of our websites and applications. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en, To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html.
We employ proportionate security measures which aim to protect the information provided by you from unauthorised or unlawful access, use, loss, disclosure, destruction or damage. However, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk.
8. Your rights
You have the right to request a copy of the personal information that we have collected and maintain about you. If you think any of the personal information we hold about you is inaccurate, you may also request it is corrected. You also have a right, in certain circumstances, to require us to stop processing your personal information. If you wish to exercise any of these rights, please email us at email@example.com. We may charge a small fee to meet out costs in providing you with these details and we may ask for proof of your identity.
Subject to applicable law, you may have some or all of the following rights in respect of your personal information:
- to obtain a copy of your personal information together with information about how and on what basis that personal information is processed;
- to rectify inaccurate personal information (including the right to have incomplete personal information completed) ;
- to erase your personal information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
- to restrict processing of your personal information where:
- the accuracy of the personal information is contested;
- the processing is unlawful but you object to the erasure of the personal information;
- we no longer require the personal information but it is still required for the establishment, exercise or defense of a legal claim;
- to challenge processing which we have justified on the basis of a legitimate interest (as opposed to your consent, or to perform a contract with you);
- to prevent us from sending you direct marketing;
- to withdraw your consent to our processing of your personal information (where that processing is based on your consent);
- to object to decisions which are based solely on automated processing or profiling; and
- to obtain, or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organisation.In addition to the above, you have the right to lodge a complaint with the supervisory authority. In the UK that is the Information Commissioner (https://ico.org.uk/).In relation to all of these rights, please email us at firstname.lastname@example.org. Please note that we may request proof of identity. We will respond to your requests within all applicable timeframes.
10. Contact Us
All comments, queries and other requests relating to our use of personal information should be addressed the customer services team at email@example.com or by post to The British Toy & Hobby Association, BTHA House, 142-146 Long Lane, London, SE1 4BS.
Our privacy officer is Matt Jones (firstname.lastname@example.org).