PIONEER THEATRES LIMITED (t/a Stratford East) Privacy Policy 

This policy was last updated on 2 July 2024 

 

Introduction 

Pioneer Theatres Ltd (“PTL”, “We”, “our”) trades as Stratford East and is a registered charity in England and Wales (charity no. 233801). We are registered with the Information Commissioners Office in respect of our obligations to safeguard your personal data and your privacy. This policy also covers all subsidiary companies of Pioneer Theatres Ltd including Stratford East (Trading) Ltd and Stratford East Productions Ltd.  

We take the privacy of everyone who engages with us very seriously and this policy outlines how Stratford East will manage all the information that we hold on you and give you further detail on how you can change how we manage that information.  

Pioneer Theatres Ltd is the ‘data controller’ for the personal information that you provide to us, that we collect, use and store. This activity is done in accordance with Data Protection law including the  Data Protection Act 2018 (DPA 2018) and The Privacy and Electronic Communications Regulations 2003 (PECR).  

Stratford East retains, collects and uses your information in order to undertake activities necessary to the theatre’s operations and development. We are committed to protecting your privacy and security, and we promise to respect any personal data you share with us. When you provide data we aim to be clear about how we will store and use it, and not to do anything with it that you would not reasonably expect.  

This policy (together with our terms and conditions) sets out the basis on which any personal data we collect from you, or that you provide to us over the internet, telephone, in person or in writing will be processed by us. We will outline what information we retain, what information we collect and from where, how we use that data and how you can contact us to change how we hold and manage your data.  

We will keep this policy updated and will review it once a year, so that you can be confident when sharing your information with us that it will only be used for the purposes outlined here. If you have any questions, please do not hesitate to contact us at: dataprotection@stratfordeast.com 

Stratford East’s contact details on information matters: 

Address: Theatre Royal Stratford East, Gerry Raffles Square, London, E15 1BN 

Email: dataprotection@stratfordeast.com 
 
 

Your rights and access to your data 

You have the right to ask for a copy of the personal data we hold about you. This is called a ‘Subject Access Request’. We may in some cases charge an administration fee, depending on the volume of work involved. You can also request to have the personal data we hold about you erased, to object to our use of your personal data, or to restrict the ways we use your personal data. You also have the right to update or correct the personal data we hold about you and where you have provided consent for us to use your personal data you always have the right to withdraw your consent at any time.  

To make any of these requests please see the further details below and the use the contact details above.   

More details on my rights and access to data 

If you would like to make a Subject Access Request to see a copy of the personal data we hold about you then you need to contact us in writing to the contact details above, with a description of the type of information you would like to see and a valid photo ID: 

• Valid passport 

• Valid driver’s licence or provisional driver’s licence 

If you do not have either of these, please contact us about other forms of acceptable ID.  

We will respond to your request as soon as possible and no longer than one month unless there are exceptional circumstances.  

If you need us to correct any mistakes contained in the information we hold about you, you can let us know by contacting us at dataprotection@stratfordeast.com 
 

You have the right to request that we erase your personal information, the right to object to our processing of your personal information and the right to restrict our processing your information in any of the ways outlined in the ‘Why we collect and use your information’ section. There may be instances where we need to retain the data in order to process it for the purposes it was provided (eg processing a donation or registering you for an event) or where we are legally required to retain it, and we will explain those to you. Requests can be made using the contact details in this policy. 

You have the right to obtain and reuse your personal data for your own use, allowing you to move, copy or transfer personal data from one IT environment to another in a safe and secure way. This only applies to data given with your consent and where processing is carried out using automated means. Requests can be made using the contact details in this policy. 

To withdraw or change your consent preferences you can use the unsubscribe link at the bottom of any marketing or fundraising emails you receive from us. Alternatively you can email dataprotection@stratfordeast.com. There are some ticketing, membership and donation communications that we may be required to send regardless or your contact preferences.  

You also have the right to request to see the legitimate interest balancing exercises we have undertaken to ensure your rights as an individual are not impacted and to object to the outcome of the exercise. For more information on legitimate interest within the DPA and our use of it, please see the ‘Why we collect and use your information’ section or alternatively visit the Information Commission’s Office website (www.ico.org.uk) 

  

What information we collect and when we collect it 

Your personal data is provided to us and collected in a number of ways. 

In most cases we store and use the personal data you give us when you decide to interact with us. This could include buying a ticket, signing up to our newsletters, becoming a member or making a donation.  

In a small number of cases further personal information may also be gathered from public sources. And there may also be instances where personal data is provided by a third party, this will mainly occur you purchase a ticket via a ticket agency or are gifted a membership.  

 

More details on information we collect 

If you buy a ticket from us you will be required to provide us with: 

• Name 

• Card number 

• Expiring Date 

• CVC 

• Billing Address 

We do not store or process your card payment details 

We will also ask you to provide: 

• Proof of age or address if you purchased tickets under a membership scheme 

• Title 

• Date of Birth 

• Email 

• Contact Number 

Some of this information you will also be asked to provide to us if you: 

• Purchase or sign up to a membership scheme 

• Donate to us 

• Sign up to receive our newsletters 

• Complete a survey 

• Sign up to education programmes 

You may provide us with and we will retain further personal information when you use the theatre, take part in our programmes, visit our website (see more details in our Cookie Policy and communicate with members of our team in person, online or by telephone. This may include: 

• Additional address and contact details 

• Family or spouse/partner details and relationships to other members, visitors and/or donors 

• Information about your use of our programmes or facilities 

• Events that you attend 

• Current interests and activities 

• Details of correspondence sent to you or received from you 

• Tax status for Gift Aid purposes 

• Details of transactions you carried out through our website, in person and over-the-phone and of the fulfilment of your orders 

  

Visual information 

We have a CCTV system in and around the theatre. Only authorised operatives have access to the system. Images are recorded for the purposes of crime prevention and public safety. 
 
We or authorised third parties may carry out photography, and film and/or sound recording in the venue. We will take reasonable steps to notify visitors of such photography or recordings including where possible information in pre event emails or by posters displayed in the building. By coming to Stratford East you consent to you and any persons (including any children) who may accompany you, being included in such recordings and such recordings subsequently being used by us for any reasonable commercial purposes, including without limitation, for marketing and promotional purposes. We will not make any payment to you in respect of your inclusion in such recordings. 

Personal data may also be gathered form public sources such as Companies House and published articles on line or printed, including social media. For more information about what we may collect from public sources see the ‘Why we collect and use your information’ section below. 

On occasion you may be part of a mailing list that Stratford East has rented, purchased or been given from a third party – in these cases you will have consented to your details being shared with Stratford East.  

In all instances we will store and use your personal data only for as long as it is relevant and accurate for its intended purposes.  

 

Special category data 

Special category data is personal data that needs more protection because it is sensitive, for example on someone’s racial or ethic origin. We will carefully consider if we need to collect this data, and will often collect it and/or keep it in an anonymised version. However, there are times where for funders, to fulfil or charitable objectives or to ensure that we are meeting key objectives we do collect Special category data. Where we do, we will ensure we meet the conditions laid out under Data Protection Law, including meeting one of the following criteria: 

• Explicit consent 

• Employment, social security and social protection (if authorised by law) 

• Vital interests 

• Not-for-profit bodies 

• Made public by the data subject 

• Legal claims or judicial acts 

• Reasons of substantial public interest (with a basis in law) 

• Health or social care (with a basis in law) 

• Public health (with a basis in law) 

• Archiving, research and statistics (with a basis in law) 

Why we collect and use your information 

The main reason for retaining, collecting and using your personal data are to fulfil your ticket purchase or membership at Stratford East, to keep you up-to-date with information, or to deliver another activity or service that you have requested or purchased. We want to ensure that we offer you a personalised experience, and inform you of any productions, activities or updates you have asked to hear about or any additional information you may need to know. We also use your personal information to understand our audiences, participants, donors, prospective donors and other customers.  

We only retain, collect and use your personal data when a legal basis has been identified for doing so, in accordance with the Data Protection Law. For most cases there are four reasons for such retention and processing that are relevant to Stratford East; this is consent, compliance with a legal obligation, legitimate interest or for contractual necessity.  

 

More details 

In many cases we retain and use your personal data to provide a service, carry out a contract with you or for administrative purposes: 

• To administer your tickets and/or membership or donations, which may be by letter, email, phone or in person 

• To ensure we are meeting your access needs 

• To send you information including Stratford East news and details of your membership 

• To thank you for a donation and acknowledge receipt 

• To administer any donations, bequests or legacy pledges you make 

• To invite you to events or that are part of the service we provide to you 

• To provide a bespoke or personalised service to you where you have joined as a member or supporter 

• To communicate with you about events for which you have purchased tickets 

• To give you information, support, services or products you ask for and are provided as part of your membership or philanthropic support 

 

If you have not purchased a ticket or signed up to an activity then we will use your personal information when you have given your consent by ticking a box on an appropriate form: 

• When you sign up to receive our e-newsletter 

• When you sign up or complete an application for L&P activities or workshops 

 
There are also occasions where we have a need to collect, store and use your personal data for compliance with our legal obligations or where we have a legitimate interest. These may include: 

• For financial processing including 

• Claiming Gift Aid on your donations where we have valid declarations 

• Collecting Direct Debit payments 

• Processing Standing Order payments 

• For internal administrative purposes and to let you know about changes to our services or policies 

• To research and statistically analyse how audiences use the theatre and how they book tickets 

• To learn about your interests and preferences so that we can ensure the marketing communications you receive from us are relevant, such as tailoring messages for particular interests of which you have notified us 

• To send you targeted promotional, direct marketing or fundraising information that are most relevant to you 

• To determine your interests and potential to support Stratford East (financially or otherwise) so that we can contact you in the most appropriate way and with then most relevant information. To help with this we may also use publicly available information such as listed directorships, geographical information, published works of references and public website profiles. Please see more information below 

• To keep a record of Stratford East membership and ticket purchases 

• Data screening and data cleaning to ensure we have accurate details for you 

• Wealth screening and research, to help us understand our members, donors and potential donors 

• To ask you to take part in surveys related to Stratford East 

 

Stratford East has always relied on membership fees and philanthropic support our artistic and community programme of work. For this to continue we will, for a small number of our members and customers, combine the information you provide with publicly available information and from business or network contacts. This is done in order to understand people’s engagement in Stratford East and ensures that we find and connect with those who have the interest and potential to support us.  

 

We will collect, store and use personal data where necessary in our legitimate interest as a charitable organisation, which might include: 

• Conducting research in order to better understand who our members and donors are, who may chose to join and support us, and better target our communications and fundraising activity 

• Monitoring who we deal with to protect our charity against fraud, money laundering and other risks 

• Maintaining and administering our donor data base 

• Assessing the likelihood of future donations 

• Briefing senior staff and trustees so that when they meet you they can tell you about areas of our work and our future plans that are most exciting and interesting to you 

• Improving our communication and fundraising content, methods, and services 

• Better understanding your interest and preferences 

• Use publicly sources images to help identify individuals who attend our special events 

 

This enables us to fulfil our legitimate interest of knowing our members, visitors, donors and potential donors; maximising the impact of our charitable resources and avoiding distress through making inappropriate approaches; while being mindful of your interests and privacy rights. In doing so we can raise more funds in a more cost-effective way. In all instances we will balance our legitimate interests as a charity against your rights as an individual, for more information please see the Your Rights section. 

 

Information we might collect includes: 

• Wealth and assets 

• Family (this does not include information about children unless given to us personally or made explicitly public by the individual consent) 

• Residential location 

• Hobbies and interest 

• Trusteeships 

• Level and frequency of gifts to Stratford East and other organisations (including political parties where they are made explicitly public by the individual concerned) 

 

Sources we might use include: 

• Companies House 

• Charity Commission and the Scottish Charity Regulator 

• Employment information you have made public 

• Other charitable organisations where you have made your philanthropic support public 

• News articles and publications 

• Your current or previous company website 

• Bloomberg and similar websites 

• Trustfunding 

 

We may on occasion use a third-party supplier to undertake these activities or analyse our data. These suppliers will be subject to contractual agreements in compliance with Data Protection regulations which includes not retaining your data after completing the activity. We will also give you the opportunity to chose not to hear from us about fundraising, other Stratford East activities or to decline further engagement with us.  

We may, in limited cases, use publicly available data sources to identify individuals who we consider may be interested in discovering more about Stratford East. In making initial contract to introduce ourselves and find out if you are interested in learning more, we would provide an early opportunity to opt-out of further communication. 

In all instances we will only store and use your personal information for as long as it is relevant and accurate for its intended purposes.  

You can opt-out of your data being utilised for prospect research, wealth screening, data cleaning, analysis with the aims of targeting communication to ensure it is appropriate and of interest, or finding up to date contact information y contacting: dataprotection@stratfordeast.com 

 

How do we keep your information safe? 

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we store.  

When we share any personal data we ensure that security is maintained through encryption. For more information on who we share your information with please see the ‘Who we share your information with’ section below. 

Debit and Credit card payments are handled by our payment partner World Pay.  
 

Organisations based inside the European Economic Area (EEA) will be subject with comparable data protection laws as those companies based in the UK. In some cases, we will engage with organisations and suppliers outside the EEA including the United States. This will include cloud-based systems, and if computer servers hosting the website are outside of the EEA. In these situations we will take steps to ensure that these suppliers provide an adequate level of protection in accordance with the UK data protection law. By submitting your personal data to us you agree to this transfer, storing or processing at a location outside UK. 

 

Who do we share your information with? 

We only share personal data that is relevant and proportionate for the practical delivery of a service. Our partners are subject to contractual agreements which help to ensure compliance with UK data protection law – this includes agreement that the third party supplier will not retain your data after the activity is completed.  

Stratford East will never sell, rent, share or trade your personal data to third parties for marketing purposes without your prior consent. On some rare occasions we may want to share your data with carefully selected partner organisations who have worked with us. In these instances we will always ask for your permission.  

 

More details 

THIRD PARTIES  
 
We work in partnership with the following 3rd party organisations who process data to facilitate direct communications, and to analyse anonymised data on our behalf. 

• These organisations will not contact you directly on behalf of Stratford East as part of any agreement with us and your data is supplied to them as instructed by us and is only retained as long as required for the provision of the services you have requested: 

 
Spektrix – provides Stratford East with a cloud based ticket booking and customer relationship management 
Purpose: ticket sales and customer relationship management software 
Information Shared: Name, address and booking information, consents 
Location: Shrewsbury, UK 
 
Sure Digital Limited - build and support our website and from time to time need access to booking records for diagnostic purposes 
Purpose: Website design and development 
Information Shared: Name, address and booking information, cookie and visits to our website 
Location: Shropshire, UK 
 
DotMailer – an email software tool with data held in the EU. Stratford East uses the software to design, deliver and manage email communications to customers. 
Purpose: Email communications 
Information Shared: Name, Address, booking information and email 
Location: London, UK 
 
Price Waterhouse Cooper Ltd - provide summary, anonymous profile reports about Stratford East’s audiences. As recipients of funding from Arts Council England we are required to provide this information to Audience Agency. 
Purpose: Analysis and audience development 
Information Shared: Account and booking information  
Location: London, UK 
 
Corporate Mailing Services Ltd - manages Stratford East’s bulk mailings to customers 
Purpose: Postal communications 
Information Shared: Name and address information  
Location: Norfolk, UK 
 
Activity Stream - provides Stratford East with a cloud-based analysis and insight tool  
Purpose: Understanding customer behaviour and identifying marketing and fundraising opportunities  
Information Shared: Information you provide when making a purchase (name, contact details, marketing preferences and consents), Location, Gender, Purchase History, Date of Birth, Record of purchases and donations, interactions with email and social media campaigns 
Location: Copenhagen, Denmark 

TicketCo – provides Stratford East with a cloud-based stream ticket booking system 

Purpose: Ticket sales for streamed performances 
Information Shared: Name, mobile number, email address, booking information 
Location: London, UK 

CrowdEngage - Provide Stratford East with a cloud-based mobile ticketing and ordering system 
Purpose: Mobile ticket fulfilment and drinks ordering  
Information Shared: Name, mobile number, email address, booking information 
Location: Cambridgeshire, UK 

INDIGO – provide summary and anonymised reports about Stratford East’s audiences when a customer choose to take part in our surveys 

Purpose: Analysis and audience development 

Information Shared: Booking information 

Location: West Sussex 

 

Monitoring website users and Cookies 

We may monitor aggregated user traffic to help us develop and improve our website. 
 
IP ADDRESSES AND OTHER SITES 

• We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregated information to our stakeholders. 

• 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 these policies.  Please check these policies before you submit any personal data to these websites. 

 

COOKIES 

Like most websites, we use ‘cookies’ to help us make our site – and the way you use it – better. These data files aren’t there to identify you, but just to make the website work better for you. They are small text files that sites transfer to your computer (or phone or tablet). They make interacting with a website faster and easier – for example by automatically filling your name and address in text fields.  

 

More details 

• For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. The cookies we use are essential for the site to operate. 

• Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Most internet browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit org 

• Stratford East website makes use of three particular types of cookies: 

• Session Cookies: These are cookies that are an essential part of our ticketing website that enable you to purchase tickets with us. These are necessary for our website to function properly, so if you do decide to turn cookies off then you will be unable to add tickets to your basket or log in to your account. 

• Google Analytics: Many organisations use this popular analytics package with their website to observe statistics and adapt online services. We do use cookies to trace traffic anonymously through our website, where the data is collated on the Google Analytics webpage. If you do not wish to participate in this, please visit this link to stop these cookies: https://tools.google.com/dlpage/gaoptout 

• Share This: This service enables you to share content via Twitter, Facebook and other social media networks. If you wish to use the ‘Share This’ functionality on our website then this will also use a cookie. If you do not wish to participate in this or would like further information on the ‘Share This’ privacy policy, please visit this link to stop these cookies: http://sharethis.com/privacy. 

• You block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. 

• However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our site. 

• Except for essential cookies, all cookies expire when you close the browser window. 

• By continuing to use our website, you consent to Stratford East collecting data via those cookies. 

 
Targeting and Advertising Cookies 

• We may use targeting and advertising cookies to serve tailored ads to you based on your previous visits to our website, or based on your demographics or interests as determined by Google*. Google uses the third-party DoubleClick cookie to collect data and serve ads that are relevant to you on the websites of its partners. The cookie does not contain any personally-identifiable information and we do not merge it with any personally-identifiable information collected through the website. Users may opt out of the use of the DoubleClick cookie for interest-based advertising by visiting Ads Settings. 

• The website uses Google Analytics Advertising Features for collecting data via Google advertising cookies and anonymous identifiers. The features used are: Remarketing with Google Analytics, Google Display Network Impression Reporting and Google Analytics Demographics and Interest Reporting. 

• *How Google determines demographic and interest information 
  When someone visits a website that has partnered with the Google Display Network, Google stores a number in their browsers to remember their visits. This number uniquely identifies a web browser on a specific computer, not a specific person. Browsers may be associated with a demographic or interest category based on the sites that were visited. In addition, some sites might provide Google with demographic information that people share on certain websites, such as social networking sites. Google may also use demographics derived from Google profiles. 

 

Where do we store your data? 

• 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. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. 

• All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using. 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. 

• Be aware that the internet and the transmission of information through the internet is not fully secure. 

• Stratford East will use reasonable endeavours to protect your personal data and prevent unauthorised access to it by storing it on a secure server which is password protected and hidden behind a firewall from the outside world, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. 

 

How long do we keep your data for? 

 
We will only hold your records during the period of our relationship with you and for a set period afterwards to allow us to meet our legal obligations including resolving any follow up issues between us. We will usually keep records about you for no longer than 6 years  

 

About this Privacy Policy 

We reserve the right to amend this privacy policy from time to time. If we make any significant changes in the way we treat your personal information we will make this clear on our website or by contacting you.  

If you have any queries about any aspect of the data we hold please contact Stratford East at dataprotection@stratfordeast.com 

 

If you wish to raise a concern about Stratford East’s handling of your data you should first contact Stratford East. If you are unhappy with the response that you receive from us, you can contact the Information Commissioner’s Office (ICO) at www.ico.org.uk or contact their helpline on 0303 123 1113.  

 

The Information Commissioner (ICO) is also a source of further information about your data protection rights. The ICO is an independent official body, and one of their primary functions is to administer the provisions of the data protection law.