HS1 Events & Competition Policy
This Events and Competition Policy is operated by HS1 Limited, whose registered office is at 5th Floor, Kings Place, 90 York Way, London N1 9AG (“HS1”).
In relation to our events, prize draws and competitions, your personal information will be held, used and processed by or on behalf of HS1 as data controller in accordance with the data protection laws of the United Kingdom.
HS1 and its partners and sponsors (who will be made known as part of the relevant event, prize draw or competition) are jointly referred to in this Policy as "We", "Us" or "Our".
This Policy sets out the purposes for which, and the manner in which, We may use personal information that is collected and obtained about you through your participation in Our events, competitions and prize draws which We operate and organise from time to time. By entering into any competition or prize draw or attending any event operated or organised by Us you consent and agree to the terms of this Policy as well as the relevant Competition Terms and Conditions and Prize Draw Terms and Conditions.
We ask that you read this Policy carefully as it contains important information about what to expect when We collect and obtain personal information about you and how We will use your personal information.
1. Use of Personal Information
Prize Draws and Competitions
When you enter into a competition or prize draw, We may collect some or all of the following information about you in order for Us to administer the competition or prize draw:
- for social media competitions we do not collect personal data until a winner has been identified;
- for website competitions, we collect your email address at the point of entry into the competition; and
- for competitions or prize draws that are run by Us or on Our behalf at Our locations
This information is collected in preparation for and as part of, and necessary for us to perform our obligations under, the contract we enter in with you in relation to the Competition Terms and Conditions and Prize Draw Terms and Conditions (as the case may be).
If you are the winner of a competition or a prize draw, We may use your name and your county of residence in announcing the winner of the prize draw. We need to do this in order to comply with the Advertising Standards Authority's requirements under the UK Code of Non-broadcast Advertising, Sales, Promotion and Direct Marketing (also known as the CAP Code). If you are the winner of a competition and have provided an image as part of the competition (e.g. a selfie in a social media competition) We may use that image in the competition winner announcement(s). This is in order for Us to pursue our legitimate interest to promote the competition results and your win, however We will always take into consideration your rights and freedoms. To the extent you do not wish Us to publish your image or would like Us to remove that image, please do let Us know by contacting Us on the details provided below.
When you attend an event operated or organised by Us, We may collect some or all of the following information about you in order for Us to administer the event: name, email address, telephone number, residential address. This information is collected in preparation for and as part of, and is necessary for us to perform Our obligations under, the contract we enter in with you in relation to the event itself. We may also process your information (including image) when We may also collect certain health information about you in order to cater for any particular requirements you may have and also in order for us to comply with our legal requirements (e.g. relating to health and safety).
When you attend an event, there may be a photographer present on Our behalf. This is necessary for us to pursue our legitimate interest to capture the particular event, the attendees and the relevant performance, activity or exhibition. We use the images in order to inform Our newsletter recipients and website visitors of the event that has taken place. We may also use the images as part of our PR releases, internal corporate presentations as well as Passenger Information Points and print media at our locations. The photographer will always ask for your verbal consent before taking photographs where you are part of the main image or in the forefront. Please do let our photographer know if you do not want your photograph to be taken. Please also be aware that depending on the photograph taken it may be that you are captured in the background of other photographs or as part of more scenic photographs. If you have any questions or concerns in relation to any photograph of you or would like to request that an image of you is removed (e.g. from our website), please do let Us know by contacting Us on the details provided below.
Please note that your image may also be captured when you attend an event as there may be CCTV cameras in operation. CCTV cameras are used at our sites to monitor any criminal activity and for health and safety reasons. If CCTV cameras are in operation, signs will be on the premises to bring this to your attention.
In accordance with your rights, We may send promotional marketing material to you after entry into one of Our prize draws or competitions. In order to do so, We may use your name and email address.
Please note that We do not want to send you information that you do not want to receive and you can opt out at any time (please see 'The right to ask us to stop contacting you with direct marketing' below for further information).
We will always ask your permission before sending you promotional marketing material. We do this by asking for your positive confirmation (e.g. by providing a tick or inserting your contact details in the relevant boxes) indicating that you wish to receive promotional marketing material. This ensures you only receive information that you have given Us permission to send and are willing to receive.
2. Disclosure of Your Personal Information
Depending on how you heard about the competition, prize draw or event, it may be that We received your personal information from a third party in the first instance. For example, it may be that you heard about us through Twitter, Facebook, Instagram, Youtube or Eventbrite. In such circumstances, your relationship with such third party will govern how they process your personal information.
In relation to the competition, prize draw or event that you participate in, We may in limited circumstances share your information with specific third parties to process your personal information on Our behalf. If We use any third parties to process your information, We will ensure that such third parties process and keep your information secure in accordance with data protection laws and the standards set out in this Policy.
As part of entering into a competition, prize draw or attending an event, you may give your information to (or We may give information about you to) companies and organisations for the following purposes:
- to store and process your personal information on systems owned by third parties that may store and process your information on Our behalf (e.g. cloud providers that provide hosting services to Us, event management companies such as Eventbrite who provide the booking platform for events on Our behalf);
- to Our employees and agents and other approved third parties to administer services provided to you by Us now or in the future (e.g. to maintain our subscriber list, distribute promotional marketing material and run campaigns for Us); and/or
- if We have a legal right or duty to disclose such information (e.g. to protect Our customers and Us from fraud and theft, We may disclose any information and data relating to you to the police or any regulatory or government authority in response to any request, including requests in connection with the investigation of any suspected illegal activities).
Certain third party providers are based or have support services located outside the European Economic Area ("EEA"). In such circumstances, We ensure that any transfer of your personal information outside the EEA is adequately protected in accordance with data protection laws.
We will ensure that our employees, agents and third parties treat all your personal information processed as set out in this Policy in strict confidence, that only those that need access have access to your personal information and that your personal information will be processed in accordance with the necessary technical and organisational security in accordance with data protection laws.
However, the internet is not a secure medium and We cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the Internet and will not hold Us responsible for any breach of security unless this is due to Our negligence or wilful default.
We do not want to keep your information for longer than necessary and as such retain your personal information for the following time periods:
- for competitions, prize draws and events we retain your personal information for 6 months; and
- if you are a competition or prize draw winner, we retain your personal information for one year (or, if longer, 3 months following the administration of the prize to ensure the full and proper administration of such prize).
5. Your rights
We have set out below your rights under data protection laws. In order to process any of the requests listed below, We may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.
The right to access information We hold about you
At any point you can contact Us to request access to the information We hold about you as well as why We have that information, who has access to the information and where We got the information. Once We have received your request We will respond within 30 days.
The right to correct and update the information We hold about you
If the data We hold about you is out of date, incomplete or incorrect, you can inform Us and We will ensure that it is updated.
The right to have your information erased
If you feel that We should no longer be using your data or that We are illegally using your data, you can request that We erase the data We hold. When We receive your request, We will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.
The right to object to processing of your data
You have the right to request that We stop processing your data. Upon receiving the request, We will contact you to tell you if We are able to comply or if We have legitimate grounds to continue. Please note that if your data is no longer actively processed, We may still need to continue to hold certain information about you in order to comply with your other rights (e.g. your name and/or email address may be on Our unsubscriber list if you chose to no longer receive marketing from us).
The right to ask Us to stop contacting you with direct marketing
You have the right to request that We stop contacting you with direct marketing. On promotional emails We always provide an 'unsubscribe' link at the bottom of the email which will unsubscribe you from that service. If you wish to opt out with respect to more than one email address, you must complete a separate request for each email address. You may also email us your request at firstname.lastname@example.org.
The right to data portability
You have the right to request that We transfer your data to another controller. Once We have received your request, We will comply where it is feasible to do so.
In those cases where We need your consent to process your information, We will ask you to make a positive indication (e.g. to tick a box or insert your contact details on the relevant form). By actively providing Us with your consent, you are stating that you have been informed as to the type of personal information that will be processed, the reasons for such processing, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject.
If for any reason you are unsure about the personal and account information We are holding in your name, please contact Us. We will happily review your file and update the records if required. You can call Us on 020 7014 2700 or email us at email@example.com.
6. Contact Us
If you have any questions/comments about this Events & Competition Policy, You can email Us at firstname.lastname@example.org. You can write to Our Data Protection Officer at HS1 Limited, 5th Floor, Kings Place, 90 York Way, London N1 9AG.
7. Changes to Policy
We keep the Policy under regular review. We may amend and update this Policy from time to time. Any changes in the future will be accessible through the HS1 website. This Events & Competition Policy was last updated on the 23rd of April 2018.