. 1.2. When we say we, our, us, or the Academy in this policy, we are referring to Delamar Academy Limited whom are “controller” of your personal data for the purposes of the Data Protection Act 1998 (Act) and the EU General Data Protection Regulation 2016/679 (GDPR) (the Act and GDPR together the Data Protection Legislation). Delamar Academy Limited (company number 05800721) The registered office of Delamar Academy is Palladium House, 1-4 Argyll Street, London, W1F 7LD.
. 1.3. Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for such websites or policies. Please check these policies before you submit any personal data to these websites.
- Personal Data We May Collect About You
2.1.We may collect and process the following personal data from you:
- Information that you provide by filling in forms on our Website, for example, your name, and contact details. This includes information provided at the time of registering to use our Website, subscribing to news and updates, posting material or requesting products and services (including facilities);
- If you register your interest in joining our courses, receiving a tour or attending an event, we might ask you to provide some of the following: your name, contact details, car registration, postal address.
- if you enroll on one of our courses we will ask you to supply your name, address, contact details, date of birth, gender, national insurance number, occupation, examinations and qualifications received, emergency contact details, special requirements, information about any conditions, languages spoken, nationality.
- Upon completing a course at the Academy, your details will be kept on file for the Delamar Agency, where we will use your contact details to offer you opportunities.
- if you contact us, we may keep a record of that correspondence;
- details of your visits to our Website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access;
- we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
- we may also ask you for information when you report a problem with our Website; and
- we also anonymise, collect, use and share aggregated data for statistical and research purposes where it does not identify you. Uses Made of the Personal Data and Legal Basis We use personal data held about you for the following purposes in line with our legitimate interests to administer the Website and to interact with users when they request our products and services, or offer to provide us with products and services:
- to provide you with opportunities and services (including courses and facilities) that you request from us, or information about them where you have asked to be contacted for such purposes;
- where you have registered your interest as an intern, event attendee, for work experience or in becoming a supplier, to assess your application and consider your suitability, to contact you in relation to your enquiry and to add you to our databases so we can contact you about potential opportunities and jobs that may be of interest;
- if you have registered to hire our classroom space, to contact you for those purposes and to administer use of our classroom space
- to ensure that content from our Website is presented in the most effective manner for you and for your computer;
- to allow you to participate in website features, when you choose to do so;
- to notify you about changes to our service; and
- in certain circumstances, to contact you with information about goods and services which we feel may interest you by post, telephone or other electronic means (e-mail or SMS) (see the section on ‘Marketing‘ below for further information). We will also use certain personal data, for example, your name and contact details, where necessary to carry out our obligations arising from any work experience or paid work into between you and an employer or potential employer
IP Addresses and Cookies
When you access our Website, we may collect information about your computer including, where available, your IP address, operating system and browser type for system administration and to report aggregate information to our advertisers. This is statistical data about our Website users’ browsing actions and patterns and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies are small text files which contain information that is transferred to your computer’s hard drive. They help us to improve our Website and to deliver a better and more personalised service. They enable us to:
- estimate our audience size and Website usage patterns;
- store information about your preferences and so allow us to customise our Website according to your individual interests;
- speed up your searches; and
- Where We Store Your Personal Data
. 3.1. All information you provide to us is stored on our secure servers.
. 3.2. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures to try to prevent unauthorised access.
- Disclosure of Your Information
. 4.1. We may disclose your personal data and most likely just your contact details to any enquiring provider of opportunities through the Delamar Agency, which means our network of designers, tutors, brands, photographers, theatre personnel, event organisers, producers or other similar individuals in the wider make-up industry.
. 4.2. We also share your personal data with the following, who act as our processors:
- our website hosting and maintenance provider;
- service providers who provide IT, software and system administration services;
- fulfilment service providers, for example e-mail marketing platforms, event invitation service providers, payment processors; and
. 4.3. Occasionally, we may need to disclose your personal data to third parties where necessary for the legitimate interests of business or in order to comply with legal obligations:
- in the event that we 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;
- if Delamar Academy Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
. 4.4. We do not disclose information about identifiable individuals to our advertisers but we may provide them with aggregated information about our Website 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 aggregated information to help advertisers reach the kind of audience they want to target (for example, women in SW1). 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 target a particular audience.
5. Overseas Transfers
The personal data we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA).
We have industry contacts in India, the United States and other countries.
o Right to object: You can object to our processing of your personal data. Please contact us as noted above, providing details of your objection.
o Access to your personal data: You can request access to a copy of your personal data that we hold, along with information on what personal data we use, why we use it, who we share it with, how long we keep it for and whether it has been used for any automated decision-making.
o Right to withdraw consent: If you have given us your consent to use your personal data – for example, to send you marketing e-mails – you can withdraw your consent at any time by clicking the “unsubscribe” link in any marketing e-mail which you receive or by contacting us as at the e-mail address noted above.
o Rectification: You can ask us to change or complete any inaccurate or incomplete personal data held about you.
o Erasure: You can ask us to delete your personal data in certain circumstances, for example where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
o Portability: You can ask us to provide you or a third party with some of the personal data that we hold about you in a structured, commonly used, electronic form, so it can be easily transferred.
o Restriction: You can ask us to restrict the personal data we use about you in certain circumstances, for example, where you have asked for it to be erased or where you have objected to our use of it.
o Automated decision-making: Automated decision-making takes place when an electronic system uses personal data to make a decision without human intervention.
You have the right not to be subject to solely automated decisions that will create legal effects or have a similar significant impact on you, unless you have given us your consent, it is necessary for a contract between you and us or is otherwise permitted by law. You also have certain rights to challenge decisions made about you. We do not currently carry out any solely automated decision-making.
o Make a complaint: You can make a complaint about how we have used your personal data to us by contacting us as noted above, or to a supervisory authority – for the UK this is the Information Commissioner’s Office, at https://ico.org.uk/.
9.0. Please note, some of these rights only apply in certain circumstances and we may not be able to fulfill every request. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
- How Long We Store Your Personal Data
10.1. We will not retain your personal data for any longer than is necessary for our purposes, including for the purposes of satisfying any legal, accounting or reporting requirements, and we have a Data Retention Policy.
10.2. In general, we hold your information for 6 years after your last contact in case of complaints or legal claims.
10.3. Where we have been using your personal data to provide you with marketing, we will retain this information for 3 years and we will delete your personal data following your request to be removed from our marketing list.