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Privacy policy

1. Policy overview
2. About us
3. Information we collect about you
4. How we collect your information
5. How we use your information
6. Who we share your information with
7. Marketing
8. Our site and cookies
9. Your rights
10. Where is your information
11. How we look after your information
12. How long we keep your information for
13. Complaints
14. Data Deletion Request

1. Policy overview

1.1 Scope of this policy
This Privacy Policy describes and oversees the nature of all information that we collect, use and otherwise process about you in connection with your relationship with us as a customer, potential customer or just an enquirer (whether as a direct booker, agent booker, site visitor or otherwise).
We are happy to provide any additional information or explanation needed and/or answer any questions you may have (please refer to the “ABOUT” section below for details on how to contact us).
1.2 Policy updates
We keep this Privacy Policy under regular review to ensure that we’re being transparent about the ways in which we use your personal information.  Any changes to our Privacy Policy will be reflected at https://www.visitballet.com/privacy-policy/  and will take effect on the date of publication. 

2. About us

2.1 Who are we?
We are Visit Ballet Limited, a company incorporated in Russia under company number 1077857034047, with our registered address as set out below.
2.2  Who's the Data Controller?
For the purposes of data protection laws, we are the “data controller” of all personal information that we collect, use and/or otherwise process about you under this Privacy Policy.
2.3 How to contact us
If you have any questions about this Privacy Policy or the ways in which we handle your personal information you may contact us as follows: 
The Data Protection Officer
Company Secretariat,
pr. Engelsa, 111, corp.1, lit. A
Saint-Petersburg 
Russia 194354
email: data.protection@visitballet.com

3. Information we collect about you

3.1 What types of information do we collect about you?
The types of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we might collect any of the following types of information:
  • Details about you. Your name, email address, telephone number, your country.
  • Your interactions with us or our partners. Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or our website, over the phone or simply verbally to our people), when you get in touch via social media, when you attend any events we host or details of your preferences or attributes based on your interactions with our website or our goods or services;

4. How we collect your information

How we might collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we collect information in any of the following ways.
4.1 Information that you provide to us:
  • When you browse our site;
  • When you book or search for goods or service via our site or via our Customer Centre;
  • When you manage your booking;
  • When you register on our website;
  • When you contact us via our call centres, social media, website, email;
  • When you ‘follow’, ‘like’, post to, or interact with our social media accounts;
  • When you participate in any of our competitions, promotions (for example via any social media channels or email) surveys or market research;
4.2 Information that we get from third parties, including:
  • A person making a booking on your behalf. We will receive personal information in the form of booking details where, for instance, a family member or friend, travel agent or employer who may be based inside or outside the EU makes a booking on your behalf;
  • Service providers. We may collect or receive personal information from our website developer and payment services provider (who may be based inside or outside the EU);

5. How we use your information

5.1 For what purposes do we use your information?
We will use your information for a variety of different purposes some of which will be dependent on the services that you engage us for. This includes:
  • To facilitate your purchase with us. We will use your information to provide you with any services that you request or purchase from us.
  • To send you service communications and support services. We will use your information to send you any communications relevant to the services or products you’ve requested or purchased from us. We will also provide you with customer service and support, deal with your enquiries, changes, complaints, comments. 
  • To manage our relationship with you. This includes notifying you of changes to our terms of use or privacy policy, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
  • To send you marketing communications.  We will use your information to keep you up to date with our latest news, offers and competitions unless you have told us that you’d prefer not to hear from us.  We may do this using analysis compiled from information we have collected from you or which we have generated about you. Please see the “MARKETING” section below for more information;
  • To process and facilitate transactions with us. We will use your information to process transactions and payments, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
  • To personalise and improve your customer experience. We will use your information to provide you with a more personalised service. (on the basis of our legitimate interests to present you with the right kinds of products and services);
  • To optimise our site. We will use your information to provide you with access to our site in a convenient and optimal matter, and with personalised content relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users);
  • To conduct research. We will use your information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you chose to participate in customer surveys, consumer focus groups and research (on the basis of our legitimate interests to improve our products, services and customer service);
  • To comply with our legal obligations, policies and procedures. We will use your information to enable us to:
-  Comply with our policies and procedures, and our legal obligations;
-  To enforce our legal rights;
This includes sharing your information with our lawyers, technical advisors, law enforcement and other regulatory bodies where necessary.
Occasionally we will use your information to make decisions about what communications you would like to receive from us in order to improve your customer experience.
 
5.2 On what grounds will we process your information?
We will use your information for the purposes listed above, either:
  • For the performance of your contract with us and the provision of our contract with you;
  • To comply with a legal obligation;
  • For our legitimate interests (we explain what we mean by this below);
  • With your consent;
5.3 What do we mean by “legitimate interests"?
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you, our customers. This involves:
  • Providing you with and improving our customer service;
  • Determining the effectiveness of our site/tools/services and improving the security and optimisation of our network, sites and services;
  • Personalizing, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing in certain circumstances, and serving you with advertising that is relevant and likely to be of interest to you;
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. We won’t use your information if we believe your interests should override ours unless we have other lawful grounds to do so.
6. Who we share your information with
In connection with the purposes and on the lawful grounds described above, we share your personal information with the following third parties:
  • Third party providers, subcontractors and suppliers that we work with. We share your information with third party suppliers that provide us with services in connection with our business and the provision of our services to you.

7. Marketing

7.1 When you’ll hear from us
We will keep you up to date with our latest news, offers and competitions if you have indicated that you are happy to receive marketing communications from us.
7.2 Opting out of marketing
If you no longer want to hear from us, you can opt-out or unsubscribe by:
Following the ‘unsubscribe’ link contained in any email marketing communications that you receive from us;

8. Our site and cookies

8.1 What we collect when you interact with our sites
As you may already know, most sites collect certain information automatically in log files about the way in which you interact with them. This includes your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to the site, number of page views, the search queries you make, and similar information.
This information will be collected by us and will be collected using cookies.
As we’ve described above, we use this information to help improve our functionality and services, run diagnostics, analyse trends, track visitor movements, gather broad demographic information and personalize our services.
8.2 What do we mean by ‘cookies’?
Cookies are small amounts of information in the form of text files, which we store on the device you use to access our site or our marketing communications. Cookies allow us to monitor your use of our services and improve them. For example, a temporary cookie is also used to keep track of your ‘session’.
We also use cookies to for site analytics purposes and to monitor how customers interact with and receive our marketing communications. We use this information to try to improve the relevance and tone of our future communications to ensure we’re servicing you as best as we can.
If you don’t want cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the ‘Help’ section of your internet browser. Please note that, if you do set your internet browser to reject cookies, you will not be able to access all of the functions of our site.

9. Your rights

9.1 Overview of your rights
You have certain rights in respect of the personal information that we hold about you, including:
  • The right to be informed of the ways in which we use your information as we seek to do in this Privacy Policy
  • The right to ask us not to process your information for marketing purposes
  • The right to request access to the information that we hold about you
  • The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect
  • In certain circumstances, the right to ask us to stop using information about you
  • The right to withdraw your consent for our use of your information in reliance of your consent
  • The right to object to our using your information on the basis of our legitimate interests and there is something about your particular situation which makes you want to object to us using it on this ground
  • The right to receive a copy of any information we hold about you in connection (or request that we transfer this to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances
  • The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances;
  • Please note that, notwithstanding these rights, we reserve the right to retain certain information for our own record-keeping and research purposes, and to defend ourselves against any legal claims. We will also need to send you service-related communications relating to your site user account even when you have requested not to receive marketing communications.
 
9.2 How to exercise your rights.
  • Contacting us. You can exercise your rights by contacting us using the details in the “ABOUT US” section above. Or, if you wish to stop receiving marketing communications, by checking the applicable boxes on forms that we use to collect your information to tell us that you don’t want to participate in marketing, clicking on the ‘unsubscribe’ link in marketing emails.
  • Updating your own details. Depending on the nature of your request, you may also be able to do update your details yourself.
  • Requesting information we hold about you. You are entitled to receive information we hold about you. You can submit a Subject Access Request by printing off, completing and sending us using the details in the ‘ABOUT US‘ section above. To help us confirm your identity and to ensure your personal data is not disclosed to anyone who does not have a right to receive it, please enclose a photocopy of your passport or any other official document upon which your signature is present with your request. Without this documentation, we may not be able to process your request.
  • We will comply with your requests unless we have a lawful reason not to do so.
  • 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. We will 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 keep you updated.

10. Where is your information

Given the international nature of our business, it may be necessary to transfer your personal information to countries outside of Russia and your country of residence.  
Data protection legislation varies among countries, with some providing more protection than others.  Regardless of where your personal information is processed, we will endeavour to ensure that any transfer of your personal information will be subject to suitable contractual provisions designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.

11. How we look after your information

11.1 Our security measures
We strive to constantly keep our security practices under review to ensure that we are keeping your information as safe as possible. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. By way of example we:
  • Ensure the physical security of our offices and sites
  • Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions
  • Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work
  • Carry out regular penetration testing of our systems and third party reviews of our software
  • Maintain internal policies and deliver data protection and confidentiality training to ensure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.
11.2 How you can help ensure the security of your information?
You too can play a part in helping to keep your information safe, including:
  • Choosing strong passwords
  • Keeping your booking references and passwords confidential, avoid sharing them with anyone else or using your password for multiple accounts
  • Limiting the information you share on social media and be conscious of using public WiFi
  • Informing us immediately if you know or suspect that your password or booking reference has been compromised, or if someone may have accessed your account
  • Keeping your devices protected by ensuring that you’re using the most up to date version of your operating system and have suitable anti-virus software if applicable
  • Keeping alert to any fraudulent emails that, although aren’t, might appear to be from us.

12. How long we keep your information for

We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims. We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example:
  • We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis unless we are required to retain it for evidential or legal purposes;
  • We retain a suppression list of individuals who no longer wish to be contacted by us indefinitely. We need to keep this information to comply with their wishes not to contact them.

13. Complaints

If you have any comments, questions or concerns about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us using the details in the “ABOUT US” section above to see if we can help resolve the issue in the first instance.

14. Data Deletion Request

To delete your data, please send us an email request to privacy@visitballet.com with either your name or email on the account. On the subject line please put "Data Deletion Request"


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