PRIVACY POLICY- FIFTH SEASON
This notice describes how we use your personal information.
This Privacy Notice last changed on 7 September 2022
Who we are
We are FIFTH SEASON LLCand we respect your privacy.
Your personal information is collected by FIFTH SEASON LLC 9560 Wilshire Boulevard Beverly Hills, CA 90210 ("we"/"us"/"our").
If you have questions, please contact us at: dataprivacy@fifthseason.com
We take our obligations under applicable law seriously. We respect your privacy and value your trustin us with regarding your personal information. This Privacy Policy sets out how we collect, hold, use and process your personal information, why we process it, the legal basis for processing, your data protection rights and control of your personal information.
DATA COLLECTION AND USAGE
We will collect store and use your personal information
• to conduct our business;
• for your access to this website
• to provide you with our newsletters if you sign up
• to meet our legal obligations;
• to use your data according to the purposes we tell you when we collect your personal information; and
• to fulfil other purposes set out in more detail in this section.
1 Collection of Personal Information:
We collect your personal information such as your name, e-mail address, account details, social media, company, password, account settings and preferences.
You give us your information to
• set up a user account;
• subscribe to email updates, newsletters or other subscriptions and features made available on our website.
We use this information to:
• create an account for you to use our website;
• manage and administer our systems;
• authenticate our consumers as genuine and to prevent fraud; and
• Send you our newsletters if you sign up;
• Our Legal Basis for using your Personal Data:
• enter into or perform our contract with you;
• comply with legal or regulatory requirements;
• our legitimate business interest
• your consent so that we can tell you about our content and send you direct marketing.
• We use your information to:
• understand how you use our website and view our content; content.
• understandwhat content you access and want to see more of
• understand and respond to consumer feedback;
• research and analyse the services our consumers want;
• direct marketing to business contacts.
2 We collect information when you attend or register to attend one of our events.
Specifically, we collect personal information you give us such as your name, address, e-mail address. We may also collect your photograph, audio and video records, and/or social media text (e.g. Twitter, Instagram).
We use this information to:
• understand your interest in our event and other future events
• send you our newsletters and direct marketing;
• share this information with third parties if you have provided your consent
• Analysisand research to better understand our consumers and their demographics, what attracts our consumers to our content, where our consumers have come from online (such as from links on other websites), and the way in which our website is used by different user groups.
• understand and respond to consumer feedback;
• marketing to business contacts
3 Information about your use of our website:
• content that you have viewed
• whether you've opened electronic communications from us;
• whether you've clicked on links in electronic communications from us;
• your preferences (or opt out) to receive marketing;
• improve our services and delivery of content to help us meet your needs and expectations based on visits to our website, your user journey and how you use our website
• develop new services based on what we learn from your activity and the activity of other consumers;
• monitor the way our websites are used;
4 How we use Your Information when you communicate with us whether in person, through our website, Apps or via email, over the phone, through social media or via any other medium, including:
• your contact details (this may include your social media account if that's the way you communicate with us);
• details of your communications with us (including when you sent it, when we received it and where you sent it from (such as our website, via email, through social media); and
• details of our messages to you.
• We use this information to:
• answer any issues or concerns;
• monitor consumer communications for quality and training purposes;
• develop new services or programming which is based on the information your provide;
5 Technical and Analytical Information that we collect through your use of the website including cookies:
• technical information, including IP address, login information, browser type and version (e.g., Internet Explorer, Firefox, Safari, etc.), time zone setting, browser plug-in types and versions, operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.), platform, device type, hardware model, MAC address, unique device identifiers and mobile network information;
• information about your visit, including the full URL clickstream to, through and from our website (including date and time);
• information about your network, such as information about devices, nodes, configurations, connection speeds, and network and application performance; and
• pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Cookies and Similar Technologies
We may automatically collect and store certain information about your interaction with our website, including IP addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamps, and related data. We use this information, which does not identify individual users, solely to improve the quality of our products and services.
Cookies and “web beacons” identify your browser collect and store information when you visit our website including information about how you use it through which it is possible to monitor your use of the website, as well as provide you with a better service and experience when browsing the website and for analytics.
Session and persistent cookies
Cookies can expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.
Session cookies – allow websites to link your actions during a browser session. They may be used for a variety of purposes such as remembering what a customer has put in their shopping basket as they browse around a site. They can also be used for security when a user is accessing internet banking or to facilitate use of webmail. Session cookies expire after a browser session.
Persistent cookies – are stored on a users’ device in between browser sessions which allow the preferences or actions of the user to be remembered on a website or in some cases across different websites. Persistent cookies are used for a variety of purposes including remembering your preferences and choices when using a site or to target advertising.
First and third party cookies – Whether a cookie is ‘first’ or ‘third’ party refers to the website or domain placing the cookie. First party cookies in basic terms are cookies set by a website visited by the user - the website displayed in the URL window. Third party cookies are cookies that are set by a domain other than the one being visited by the user. If a user visits a website and a separate company sets a cookie through that website this would be a third party cookie.
We use persistent cookies to recognise you and provide you with a good user experience. We also
Web beacons (also known as "single pixel GIFs", "clear GIFs" or "tags") are small graphic images that may be included on our website. Web beacons:
• allow us to optimise our products and services;
• provide us and third-party partners with analytics information, such as how many visitors our website receives; and
• are used by us in our email correspondence to determine whether you open them or take any further action.
We also work with other organisations to place our cookies and web beacons on their websites or in their advertisements. We do this to help us develop statistics on how often clicking on an advertisement on our websites results in a purchase or other interaction on the advertiser's website.
For more information about cookies and how we use them, please see our Cookie Notice.
Legal Basis for Using this Information:
• your consent to non-recurring Cookies via the cookie banneron our site;
• contract completion;
• legal or regulatory requirements;
• fraud prevention and detection
• legitimate business interest to:
• understanding how our consumers use our products, services, Apps and websites
• tell you about the various products and services we can offer;
• provide network and information security;
• assess the number of visitors, posts, page views, reviews and followers in order to optimise marketing on the web or through social media;
• direct marketing to business contacts.
6 Information that we collect from individuals representing organisations, including:
• contact details of individuals working for organisations;
• other personal information regarding such individuals.
We use this information to:
• build relationships with other organisations;
• provide marketing communications to these individuals;
• improve our services and develop new services based on the preferences and behaviours of these individuals.
We use this information because:
• we have a legitimate business interest to:
• develop and maintain relationships with vendors, partners and other companies;
• deal with individuals who work for organisations in our sector
• conduct research to improve our services;
• trade organisation and industry events
OTHER SOURCES OF DATA
Your personal information is either (a) by you to other organisations who have your permission to share your data; (b) social media; (c) obtained from other companies in our group (if we tell you who they are at the time your sign up to our website); (d) data from credit agencies (e.g. Experian) or other demographic agenciesor (d) obtained from publicly available sources e.g. the Internet, government publications.
Data may also be obtained from the following third parties: social networks, Google Analytics, Adobe Analytics, Experian and others.
Any personal information you supply to us through our website / platform/ App must be complete and accurate. You also agree to allow us to contact you to verify your personal information, if we need to.
HOW LONG WE KEEP YOUR INFORMATION
We generally keep information as needed to provide services and to deal with litigation.
We will keep your information for as long as it is reasonably necessary to provide you with services and content and to deal with legal claims or as required by law or regulation.
It will depend on factors such as whether you've got an account with us, have interacted with recent offers or have attended our recent events. We will also retain your information as necessary to comply with legal, accounting or reporting requirements. We will retail your information until you opt out or unsubscribe from our services.
We will also retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a legal matter. It will continue to be stored until those issues are fully resolved.
Legal and Other Requirements
In some cases we need to collect or retain personal information for legal reasons.
Some of the personal information we request is required to provide the services and if not provided, we may not be able to provide our content to you or provide information you have requested from us.
In other cases, for example, when we request your personal data to send you marketing and promotional communications, the lack of such information will mean it is impossible to send you these, but it will not have any consequence to the primary purpose of the data collection (to provide you with content).
Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, or in order to investigate, prevent or take action regarding suspected illegal activities or fraud, to enforce our Terms of Use and other agreements, , to protect the rights, property or safety of group companies, consumers, clients and others or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute or until applicable law allows it to be deleted. It will continue to be stored until those issues are fully resolved and it can be lawfully deleted.
INFORMATION WE SHARE
There are certain circumstances where we transfer your personal data to employees, contractors and to other parties.
• We share information about you with other members of our group of companies so we can provide the best service across our group. They are required to keep and use your information in accordance with this Privacy Notice
• We share aggregated, anonymised or other de-identified data with advertisers, advertising networks and social networks that require the data to select and serve relevant adverts to you and others. We will also use aggregate information to help advertisers reach the kind of audience they want to target.
We make use of the personal information we have collected from you to help our advertisers display their advertisements to a target audience and to present our promotional messages to you including using Facebook Custom Audience. This means you will be presented with advertisements that are more relevant to you as a result of the personal information we hold about you. We share your personal data with and access information from analytics and search engine providers that assist us in the improvement and optimisation of the website and the app and for better personalisation of content and advertising. We share your information with certain contractors or service providers, for example, if we use a marketing agency, advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, email providers and outsourced call centres. Our suppliers and service providers are required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function and are prohibited from using your information for any purposes other than those outlined in this Privacy Notice.
Your personal information may be transferred to other third party organisations in certain scenarios:
Proposed sale of part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality; Corporate reorganisation or sale,your information may be transferred to the buyer to continue to provide services to you; if we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority; if we are involved in a legal matter inan emergency including which requires us to share your data to protect the health and safety of our website's 's users or the general public. Anonymised data. If personal data is anonymised it is no longer personal data and may be shared with third parties.
WHERE YOUR INFORMATION WILL BE HELD
If you are a European Citizen, the information that we collect from you inEuropean Economic Area (EEA)may be transferred to and stored at a destination outside theEEA , including the USA which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the EEA who work for us, for one of our affiliated companies, or for the organisation that hosts our website.
However, to ensure your personal information is properly protected in line with EU data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation.
We will only transfer data collected in the EEA to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.
If you would like to obtain copies of the regulator-approved SSCs please contact us on the contact details below.
YOUR DATA PROTECTION RIGHTS
You may have certain rights in relation to your information under state, Federal or EU Data Protection Law. The availability of these rights and the ways in which you can use them are set out below in more detail.
Some EU rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact the Privacy Counsel, EMEA at dataprivacy@fifthseason.com.
Access: you can ask us what personal data we hold on you and request a copy of that information. Correction: you can request that any incomplete or inaccurate personal information we hold about you is corrected. Erasure (Right to be Forgotten): you can ask us to delete or remove the personal information you have given us. We may not erase where the personal data is required for compliance with law or in connection with claims. Restriction: you can ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it. You may also withdraw your consent for our use of your information for direct marketing or any other consent you have given for processing. Transfer: you may request the transfer of certain of your personal information to another party. Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. If you want to exercise any of these rights, please contact the Privacy Counsel, EMEA, in writing at dataprivacy@fifthseason.com and complete our Individual Rights Request form.
You can complain to an EEA supervisory authority, in particular in the Member State in the European Union where you reside, where an alleged infringement of Data Protection law has taken place or where we have an office. For the UK, you can make a complaint to the Information Commissioner's Office (Tel: 0303 123 1113 or at www.ico.org.uk).
RIGHT TO OBJECT
You have a right to object to us processing your information in certain circumstances.
Opt Out of Marketing. You can opt-out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online accounts settings page, clicking on the "unsubscribe" link included at the end of any marketing email we send to you, or by contacting the Privacy Counsel, EMEA by email at dataprivacy@fifthseason.com com or by mail to: FIFTH SEASON 9560 Wilshire Boulevard Beverly Hills, CA 90210
SECURITY
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted through our platform /App / website and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access.
LINKS TO THIRD PARTY WEBSITE
Our website, newsletters, email updates and other communications may contain links to and from the websites of third parties including our partner networks, advertisers and other group companies and/or social networks as offered to you and supported by your browser (“Third Party Websites”).
The personal data that you provide through Third Party Websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility
CHILDREN
We do not knowingly collect information from children or other persons who are under 18 years old. If you are under 18 years old, you may not submit any personal information to us or subscribe for the services.
CHANGES TO THIS NOTICE
This notice may be changed from time to time.
We may change this Privacy Policy from time to time and will highlight significant changes to you. We may also notify you in advance of the changes taking effect so that you understand what impact our changes may have on you. Once this notice is posted on our website, it will automatically come into force. The latest version of this notice will prevail over all previous versions.
HOW TO CONTACT US
If you would like more information about the way we manage personal information that we hold about you, or wish to request action on your Data Subject Rights, please contact us at Privacy Counsel, EMEA: by email to dataprivacy@fifthseason.com com or by Post in EU to Data Privacy c/o Legal 7-10 Beaumont Mews, London, W1G 6EB or mail to FIFTH SEASON 9560 Wilshire Boulevard Beverly Hills, CA 90210.
Complaint to Regulator: you can complain to the EU regulator where you reside.