The Small Print

The Bath Masonic Hall Trustee Company Limited respects your privacy and is committed to protecting your personal data.   This policy (together with our Terms of Use and any other documents referred to on our website) sets out the basis of how we look after your personal data when you visit our website (regardless of where you visit it from) and tells you about your privacy rights and how the law protects you.   Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

Important information and who we are

This website is operated by The Bath Masonic Hall Company Limited. You can contact us at the postal or email address that can be found by following this link.

Purpose of this Privacy Policy

This privacy policy aims to give you information on how The Bath Masonic Hall Trustee Company Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you [sign up to our newsletter, purchase a product or service or take part in a competition].

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy supplements the other policies and is not intended to override them.

Controller

The Bath Masonic Hall Trustee Company Limited is the controller and responsible for your personal data (collectively referred to as “The Bath Masonic Hall Trustee Company Limited ”, “we”, “us” or “our” in this notice).   We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Data Protection Officer
The Bath Masonic Hall Trustee Company Limited
12 Old Orchard Street
Bath
BA1 1JU

email: sec@bathfreemasons.co.uk

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

This version was last updated on the date shown at the foot of the page and historic versions can be obtained by contacting us.   The data protection law in the UK changes on 25th May 2018, and this privacy policy sets out your rights under the new laws.

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.

Third-party links

This website includes links to external third-party websites and/or applications.  External links from this website are always opened in a separate browser window or tab which transfers you to the external website in a different browser session.    We do not control those third-party websites and are not responsible for their privacy statements, and clicking on the links and/or enabling those external browser sessions may allow third parties to collect or share data about you.  When you leave our website, we encourage you to read the privacy policy of every website you visit.

Information we collect from 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 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 offences.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data which can include first name, last name, username or similar identifier and title.
• Contact Data which can include correspondence address, email address and telephone numbers.
• Financial Data which can include bank account and payment card details.  Please note that we do not currently collect any Financial Data through this website.
• Transaction Data which can include details about payments to and from you and other details of products and services you have purchased from us.   Please note that we do not currently collect any Transaction Data through this website.
• Technical Data which can include 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 which can include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.  Please note that we do not currently collect any Profile Data through this website.
• Usage Data which can include information about how you use our website, products and services.
• Marketing and Communications Data which can include your preferences in receiving marketing from us and our third parties and your communication preferences.   Please note that we do not currently collect any Marketing Data through this website.

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 policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services).  In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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 personal data by filling in forms on http://oldtheatreroyal.com (our site) or by corresponding with us by telephone, email or otherwise.  This includes personal data you provide when you: apply for a quotation; apply for our products or services; give us some feedback; register to use our site; create an account on our website;  subscribe to our services or publications; request marketing to be sent to you; participate in discussion boards or other social media functions on our site; enter a competition, promotion or survey; when you report a problem with our site.  The information you give us may include your name, address, e-mail address and telephone number, financial and credit card information, personal description and photograph, and/or information to assist in the detection of fraud or other abuses.

Automated technologies or interactions:   As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.  For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy.

Third parties or publicly available sources:

We do not currently seek or receive personal data from any third party via this website.  We may, however, solicit and/or receive personal data from public sources, such as Companies House and/or the Electoral Register, based inside the EU, that are necessary for our legitimate interests (eg: for network security, to prevent fraud and/or to comply with a legal obligation.)

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform a contract we are about to enter into or have entered into with you.  This 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.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.   “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 and most secure experience.  We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.  We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  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

Where we need to comply with a legal or regulatory obligation.   This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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 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 customer	Identity Data; Contact Data	Performance of a contract with you
To process and deliver your contract or order, including to: 1. Manage payments, fees and charges 2. Collect and recover money owed to us	Identity Data; Contact Data; Financial Data; Transaction Data*; Marketing & Communications Data*	(a) Performance of a contract with you (b) Necessary for our legitimate interests (eg: to recover debts due to us)
To manage our relationship with you which will include: 1.  Notifying you about changes to our terms or privacy policy 2. Asking you to leave a review or take a survey	Identity Data; Contact Data; Profile Data*; Marketing & Communications Data*	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (eg: to keep our records updated)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Data; Contact Data; Technical Data	(a) Necessary for our legitimate interests (eg: for provision of IT services, network security and to prevent fraud) (b) Necessary to comply with a legal obligation
To deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you	Identity Data; Contact Data; Technical Data; Profile Data*; Usage Data; Marketing & Communications Data*	Necessary for our legitimate interests (eg: to develop our products/services, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	Usage Data; Technical Data	Necessary for our legitimate interests (eg: to define types of customers for our products and services and to keep our website updated and relevant)
	*We do not currently collect this data through this website

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.    Please note, however, that we do not currently collect or process any Marketing Data through this website.

You will receive marketing communications from us only if you have requested information from us.

Third-party marketing:  We do not currently share any personal data with any company outside of [the] The Bath Masonic Hall Trustee Company Limited [group of companies] for marketing purposes.

[We will get your express opt-in consent before we share your personal data with any company outside the The Bath Masonic Hall Trustee Company Limited group of companies for marketing purposes.]

Opting out

You can opt-out of receiving any communication from us by either selecting or unselecting the relevant boxes on any contact form on this website, or  by contacting us at any time.

Disclosure of personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties:  other companies that at any time are in a legally-formed group of companies that includes The Bath Masonic Hall Trustee Company Limited Group and  acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.   This includes our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, should such exist.

External Third Parties:

• Service providers based the United Kingdom who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Specific third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Analytics and Search Engine providers that assist us in the improvement and optimisation of our site;
• Credit Reference Agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
• 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 policy;
• Legal Obligation:  If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of The Bath Masonic Hall Trustee Company Limited, our customers, or others.  This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

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.

Where we store your personal data

Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.   All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

International transfers

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”).  It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.  This includes staff engaged in, among other things, the provision of support services.   Whenever we transfer your personal data out of the EEA, 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 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.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, 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.

Data retention

We will only retain your personal data for as long as necessary to fulfil 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 unauthorised 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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can request erasure of your personal data. See the section on your legal rights below for further details.

In some circumstances we may anonymise 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.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.    If you wish to exercise any of the rights set out above, please contact us. Please read the following to find out more about these rights, under which you can:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you.  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.
• Request erasure of your personal data. 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 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 of your personal data. 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 of your personal data to you or to a third party. 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 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Our site 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 those policies. Please check those policies before you submit any personal data to those websites.

Access to information

Your right of access to information can be exercised in accordance with the appropriate legislation enacted at the time of exercise.   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 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.

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 keep you updated.

Changes to our Privacy Policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.   Please check back frequently to see any updates or changes to our privacy policy.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to the postal or email address that can be found by following this link.

This Policy completely revised and reissued on 15^th May 2018

Information about our use of Cookies

A cookie is a small file, typically of letters and numbers, downloaded to a device when you access a website and are useful because they allow a website to recognise a user’s device. Cookies are then sent back to the originating website on each subsequent visit.

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website.  Some are essential, while others you can opt out of or block.  However, opting out or blocking some cookies may affect the functionality of the website.

There will also be other third party cookies that we have no control over, which record your visit to our website, the pages you have visited and the links you have followed. These include:

• Cookies placed by your selected browser application in conjunction with your access of this, and any other, website during your current browser session
• Cookies placed by a search engine that you are utilising during the same current browser session
• Cookies placed by a social media site that you are logged-in to during the same current browser session.

To find out more about the third party cookies placed on your device under those three criteria, you will need to consult the manufacturer’s privacy policies for the browser application you select, such as Explorer, Firefox, Safari or Chrome, the search engine application you utilise, such as Google or Bing, or your preferred social media site such as Facebook, Twitter, Instagram or Google-Plus.

In addition, where external links are provided to other websites to provide additional information, those websites, if accessed, may use additional cookies.  External links are always opened in a separate browser window or tab to enable the user to establish settings or view policies prior to deciding whether to continue using the external website.

How to control cookies

The simplest way to avoid the use of cookies is to open a ‘private browsing’ / ‘incognito’ session, which allows you to browse a website without storing local data.  Alternatively you can control cookies which are set during your use of a website by changing your browser settings to do any of the following:

• Allow all cookies at all times
• Clear all cookies when you close a browser session
• Block third-party cookies at all times
• Block all cookies at all times
• Delete all cookies stored on your device

Some pages may not work if you completely disable cookies, but many third party cookies can be safely blocked.  Specific instructions on how to manage cookies are included in the help section of your selected browser.   You may also install add-ons and plug-ins to extend browser functionality, details of which will be available from your selected browser manufacturer.

Why and how we use cookies

There are broadly four reasons why a cookie might be stored on your device when visiting the website.  Our website may, from time to time, use any of the following types of cookies:

Strictly-necessary cookies: These are cookies that are required for the operation of the website, including session cookies created by our webservers, security plugins, etc. They include, for example, cookies that enable you to log into secure areas of the website, use a shopping cart or make use of e-billing services.   The strictly-necessary cookies we use are:

Name	Data stored	Purpose	Expires
PHPSESSID	A random unique number or string of letters and numbers	A session cookie is required to follow your progress through the website. It is essential to ensure that any information you enter or routes you take are remembered by the website. Without this cookie, every page you visited would treat you as a completely new visitor. This cookie does not identify you personally and is not linked to any other information we store about you	The cookie is deleted when you close your web browser
wordfence_verified	Unique identifier	Wordfence security cookie helps the website verify if the visitor is human or not so as to proceed accordingly	The cookie is deleted when you close your web browser
wfvt_	A random unique number or string of letters and numbers	Wordfence security cookie tracks user duration so that so that page views can be grouped together	The cookie is deleted when you close your web browser

Analytical/performance cookies: These cookies collect data about your use of the website which is then anonymised and amalgamated with that of other visitors so we can better understand how people use our website.  This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. The tool we use is Google Analytics, which utilises the following analytical/performance cookies:

Name	Data stored	Purpose	Expires
_ga _gali _gat _gid __utma __utmb __utmc __utmt __utmv __utmz	A random unique number or string of letters and numbers	The data collected by Google Analytics is used to determine which domain to measure, distinguish unique users, throttle the request rate, determine the start and end of a session, remember the number and time of previous visits, remember traffic source information  and remember the value of visitor-level custom variables. This information is combined with data from thousands of other users to create an overall picture of website use, and is never identified individually or personally and is not linked to any other information we store about you.  Information about your use of our website, including your IP address, may be transmitted to Google and stored on servers in the United States.	Most expire between a day and up to two years after your last visit to the website. Others are deleted within 30 minutes of the moment you close your browser

Functionality cookies: These remember your preferences and make the site easier for you to use.

Name	Data stored	Purpose	Expires
Local storage	text strings	This is not a cookie but an area created on your device by some browsers to store information such as user preferences and/or consent on loading specific features. This consent is requested the first time the user loads a page which uses a relevant feature	Never, but content can be deleted using browser settings

Targeting cookies: Cookies that are placed by third party services we make use of to enhance the information we present online, such as Maps and/or Videos. You can find more information about the individual Targeting cookies we use and the purposes for which we use them in the table below:

Name	Data stored	Purpose	Expires
PREF	Stores your options such as preferred zoom level if you change them from site presets	Google set this cookie on any page that includes a Google Map. We have no control over the cookies set by Google.	Expires 6 months after your last visit to a page containing a Google Map
GPS IDE PREF YSC test_cookie VISITOR_INFO1_LIVE	Unique identifiers, as well as login information that may relate to a Google account	Google set a number of cookies on any page that has a Youtube video embedded.  We have no control over the cookies set by Google, which include pieces of information to measure the number and behaviour of Youtube users, plus information that links your visits to our website with your Google account if you are signed in to one	Most expire two years after last visit to a page containing a Youtube video, although some expire sooner
vuid	unique identifier	Activated when an embedded Vimeo video is played to hold information about current viewing video settings	Two years after the last viewing of a video

This Policy completely revised and reissued on 15^th May 2018

Accessibility of websites is assessed  by the manner in which a web user perceives information is affected by their own abilities and/or disabilities.  This is primarily dependent on the methodologies utilised by users, including the elderly and disabled, to navigate and use a website and the pages it incorporates and/or links to.

AbilityNet, a UK-registered Charity, have produced a comprehensive guide to the many adjustments to make your computer, laptop, tablet and smartphone easier to use. This guide, entitled MyComputerMyWay, covers how to get the most of the accessibility features and assistive technologies available for your computer, operating system and web browser. The following topics are covered:

• Vision Assistance
• Hearing Assistance
• Motor Assistance
• Cognitive Assistance

For further information MyComputerMyWay can be viewed here

This Policy last revised on 24^th May 2018

Company Information

This website is operated by The Bath Masonic Hall Trustee Company Limited.  Statutory information can be found by following this link.