Privacy Policy

1. Overview

The Aaron Dwyer Company respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store, share and protect personal data when you:

• visit our website;
• download an information pack;
• make an enquiry;
• create an account;
• enter or attend a dance competition;
• purchase tickets, workshops, programmes or other services;
• participate in a training programme, production or performance;
• communicate with us;
• subscribe to marketing;
• work with us as a studio, teacher, contractor, judge, chaperone, supplier or venue; or
• otherwise interact with The Aaron Dwyer Company.

This policy applies to our activities in the United Kingdom, including Northern Ireland, the Republic of Ireland and other countries in which we provide events or services.

This policy should be read alongside any event terms and conditions, safeguarding information, photography notices, cookie policy or other information provided when personal data is collected.

2. Who Is Responsible for Your Personal Data?

For data-protection purposes, the controller of your personal data is:

Aaron Dwyer trading as The Aaron Dwyer Company

Trading name: The Aaron Dwyer Company

Online: Contact form

Telephone: +44 (0)7375 947708

Postal address: 167–169 Great Portland Street, 5th Floor, London, W1W 5PF

In this policy, “The Aaron Dwyer Company”, “we”, “us” and “our” refer to the controller identified above.

We have not appointed a formal Data Protection Officer. Privacy questions, rights requests and complaints should be directed to our Data Protection Contact using the details above.

3. Data-Protection Principles

When processing personal data, we aim to ensure that it is:

• used lawfully, fairly and transparently;
• collected for clear and legitimate purposes;
• limited to what is reasonably necessary;
• accurate and kept up to date;
• retained only for as long as necessary;
• protected against unauthorised access, loss or misuse; and
• handled in a way that allows us to demonstrate compliance.

4. Our Relationship With Dance Studios and Teachers

Dance studios, schools, teachers and group organisers may provide personal data to us when registering dancers or arranging attendance at an event.

Depending on the circumstances, the studio or organiser and The Aaron Dwyer Company may each act as separate data controllers.

The studio, school, teacher or organiser is responsible for:

• ensuring that it is authorised to provide participant information to us;
• informing participants and parents or guardians about the event;
• providing appropriate privacy information;
• ensuring that information submitted is accurate;
• obtaining required participation and media permissions;
• notifying us of relevant medical, accessibility or safeguarding requirements; and
• passing important event and privacy information to participants and parents or guardians.

Once we receive personal data for our own event administration, safety, contractual and business purposes, we are responsible for how we process that information.

5. Personal Data We May Collect

The information we collect depends on how you interact with us.

5.1 Identity Information

This may include:

• first name;
• surname;
• preferred name;
• title;
• date of birth;
• age or competition age category;
• gender, where relevant to the service;
• studio or organisation;
• job title or role;
• username; and
• participant or customer reference numbers.

We will only collect information such as gender where it is relevant and appropriate.

5.2 Contact Information

This may include:

• email address;
• telephone or mobile number;
• postal address;
• billing address;
• emergency contact details;
• social media username; and
• communication preferences.

5.3 Competition and Event Information

This may include:

• event entered or attended;
• studio affiliation;
• participant names;
• age groups and divisions;
• dance styles and categories;
• routine titles;
• music information;
• workshop choices;
• running orders;
• attendance records;
• ticket information;
• competition scores;
• rankings and results;
• awards, titles and scholarships;
• judges’ comments;
• audio feedback;
• entry history; and
• information required to administer an event.

5.4 Children’s Information

Many of our events and programmes involve children and young people.

Information about a child may include:

• name;
• date of birth or age;
• dance studio;
• parent or guardian information;
• emergency contacts;
• event entries;
• performance information;
• attendance records;
• competition results;
• photographs and recordings;
• medical or accessibility information;
• safeguarding information; and
• information required for child-performance licensing or chaperone arrangements.

We aim to collect only the information reasonably required to administer the event, programme or service safely.

5.5 Health, Medical and Accessibility Information

Where necessary, we may collect:

• medical conditions;
• disabilities;
• access requirements;
• allergies;
• medication information;
• injuries;
• dietary requirements;
• emergency treatment information; and
• accident or incident details.

Health and disability information is given additional protection under data-protection law.

Please do not provide medical information that is not relevant to participation, accessibility, safeguarding or emergency arrangements.

5.6 Payment and Transaction Information

This may include:

• purchases;
• deposits;
• instalments;
• payment status;
• refunds;
• invoice information;
• billing details;
• transaction references; and
• correspondence concerning payments.

Payments are normally processed through specialist payment providers.

We do not ordinarily receive or store complete debit-card or credit-card information.

5.7 Account and Profile Information

This may include:

• account username;
• encrypted password or authentication information;
• registration history;
• purchases;
• preferences;
• interests;
• feedback;
• survey answers; and
• account settings.

You are responsible for keeping your account credentials confidential.

5.8 Communications

We may retain:

• emails;
• letters;
• telephone notes;
• WhatsApp messages;
• social media messages;
• enquiry forms;
• complaints;
• customer-service messages; and
• records of our responses.

Telephone or online calls will not ordinarily be recorded unless you are informed in advance.

5.9 Website and Technical Information

When you use our website, we may collect:

• internet protocol address;
• device type;
• browser type;
• operating system;
• approximate location;
• pages visited;
• links selected;
• referring website;
• login activity;
• cookie identifiers;
• website interaction data; and
• security and diagnostic information.

5.10 Marketing Information

This may include:

• marketing permissions;
• subscription status;
• communication preferences;
• events or programmes of interest;
• information-pack downloads;
• email engagement;
• link selections;
• previous enquiries; and
• previous bookings or purchases.

5.11 Photography, Video and Audio

This may include:

• professional event photographs;
• performance recordings;
• promotional videos;
• audience or venue footage;
• awards presentations;
• interviews;
• testimonials;
• livestream footage;
• social media content;
• judges’ audio feedback; and
• photographs or recordings provided by studios or participants.

5.12 Safeguarding and Incident Information

Where necessary, we may process:

• safeguarding concerns;
• accident and injury reports;
• behavioural incidents;
• complaints;
• alleged misconduct;
• witness accounts;
• lost-child information;
• insurance matters;
• communications with studios or parents; and
• information shared with safeguarding or regulatory authorities.

Access to safeguarding and incident information is restricted.

5.13 Staff, Contractor and Supplier Information

Where somebody works with us or applies to do so, we may collect:

• contact details;
• work history;
• qualifications;
• references;
• identification;
• bank details;
• tax information;
• right-to-work information;
• insurance information;
• safeguarding or background-check information;
• contracts;
• availability; and
• performance or conduct information.

6. How We Obtain Personal Data

We may obtain personal data:

Directly From You

For example, when you:

• complete a website form;
• download an information pack;
• register for an event;
• buy a ticket;
• create an account;
• contact us;
• subscribe to communications;
• provide feedback; or
• attend an event.

From Studios, Teachers and Organisers

A studio, teacher, school or organiser may provide participant information when making an entry or booking.

From Parents and Guardians

A parent or guardian may provide information about themselves, a child or an emergency contact.

You should only provide another person’s information where you are authorised to do so.

Automatically

We may collect technical information through:

• cookies;
• website analytics;
• pixels;
• server logs;
• security tools; and
• similar technologies.

From Service Providers and Event Partners

We may receive information from:

• registration platforms;
• ticketing providers;
• payment providers;
• competition-management systems;
• venues;
• photographers;
• videographers;
• marketing platforms;
• analytics providers; and
• organisations helping us deliver an event.

From Public Sources

Where lawful and appropriate, we may obtain professional or business contact information from:

• business websites;
• studio websites;
• public directories;
• professional social media profiles;
• Companies House; and
• other publicly available sources.

7. How We Use Personal Data and Our Lawful Bases

We only use personal data where we have a lawful reason to do so.

The lawful basis will depend on the purpose and circumstances.

8. Contractual Information

Certain information is required so that we can:

• accept an entry;
• complete a booking;
• process a payment;
• issue a ticket;
• arrange attendance;
• provide feedback;
• manage safety; or
• deliver an event or programme.

Where required information is not supplied, we may be unable to accept or continue a booking, entry or participation.

9. Legitimate Interests

Where we rely on legitimate interests, those interests may include:

• operating safe and professionally managed events;
• responding to enquiries;
• maintaining accurate booking and competition records;
• protecting participants, staff and property;
• improving our events and services;
• recognising participant achievements;
• preventing fraud;
• securing our systems;
• resolving complaints;
• promoting relevant services;
• maintaining an event archive; and
• protecting or enforcing our legal rights.

Before relying on legitimate interests, we consider:

• whether the use is necessary;
• what the individual would reasonably expect;
• whether a less intrusive method is available;
• the sensitivity of the information;
• whether the information concerns a child;
• the possible impact on the individual; and
• what safeguards should be applied.

10. Health and Other Special Category Information

Information concerning health, disability, racial or ethnic origin, religion, sexual orientation and certain other matters is described as special category personal data.

We will only process special category information where:

• there is an ordinary lawful basis for the processing;
• an additional legal condition applies;
• the information is reasonably necessary; and
• appropriate protections are in place.

For our services, this will most commonly concern:

• health conditions;
• disabilities;
• injuries;
• allergies;
• medication;
• accessibility arrangements; and
• dietary requirements linked to health or religion.

We will not use health, disability or safeguarding information for advertising or unrelated marketing.

11. Children and Young People

We recognise that children’s personal data requires particular protection.

Registrations

Unless we expressly state otherwise, a booking or entry for a participant under 18 must be submitted or authorised by:

• a parent or legal guardian;
• an authorised dance studio;
• a teacher;
• a school; or
• another responsible adult with appropriate authority.

Responsibility of Studios and Organisers

When submitting a child’s information, a studio or organiser confirms that it:

• is authorised to enter the child;
• has informed the child’s parent or guardian;
• is authorised to share the information with us;
• has obtained any required permissions;
• has provided relevant event and privacy information; and
• will notify us of restrictions affecting participation, photography or safeguarding.

Best Interests of the Child

When processing children’s information, we consider:

• the child’s age and understanding;
• the child’s best interests;
• the sensitivity of the information;
• why the information is required;
• the potential impact on the child; and
• whether additional safeguards are necessary.

Children’s Rights

Data-protection rights belong to the child.

A parent or guardian may exercise those rights on the child’s behalf where appropriate. As a child becomes older and more capable of understanding the processing, the child’s own views may carry greater weight.

We may request evidence that a person is authorised to act on behalf of a child.

Direct Marketing

We do not knowingly direct individualised marketing at young children.

Marketing for children’s events will normally be directed to parents, guardians, teachers, studio owners and responsible adults.

12. Photography, Filming and Event Recording

Our competitions, workshops, productions and other events may be photographed, filmed, recorded or livestreamed.

Photography and recordings may include:

• performances;
• workshops;
• audience areas;
• awards presentations;
• interviews;
• testimonials;
• behind-the-scenes content;
• venue footage; and
• general event coverage.

How We May Use Images and Recordings

Images and recordings may be used for:

• documenting an event;
• delivering purchased recordings or photographs;
• recognising achievements;
• reporting competition results;
• safeguarding and incident investigation;
• printed programmes;
• information packs;
• websites;
• social media;
• promotional videos;
• digital advertising;
• email marketing;
• press and public relations; and
• promotion of future events.

Our Lawful Basis

The lawful basis will depend on the nature and intended use of the image.

We may rely on legitimate interests for proportionate general event coverage, event reporting and documentation where the rights of those appearing in the content are properly considered.

We may request consent for:

• planned close-up promotional photography;
• individual interviews;
• testimonials;
• specifically commissioned marketing content; and
• other uses where consent is the most appropriate basis.

We will take particular care where identifiable children are the main subject of promotional content.

Attendance at an event will not be treated as unlimited consent to every possible use of an image.

Event Notices

Photography and filming information may be provided through:

• booking forms;
• event terms;
• studio communications;
• venue signs;
• event programmes;
• announcements;
• wristbands or identifiers; and
• direct communication.

Objections

A participant, parent or guardian may notify us in writing before an event where there is a specific objection to promotional photography or filming.

We will take reasonable steps to respect valid objections. Measures may include:

• notifying the event photographer;
• using an identifier;
• avoiding planned individual photography;
• excluding the participant from arranged promotional content; or
• reviewing identified content before publication where reasonably possible.

We cannot guarantee exclusion from:

• wide-angle crowd images;
• background footage;
• livestreams;
• group photographs;
• recordings already distributed;
• incidental footage; or
• photographs taken independently by audience members.

Audience Photography

Audience members are responsible for their own photography, recordings and social media activity.

They must comply with:

• venue rules;
• event instructions;
• safeguarding requirements;
• copyright restrictions; and
• applicable law.

We may restrict audience photography or filming where necessary.

Withdrawal of Consent

Where an image is used on the basis of consent, consent may be withdrawn by contacting us.

Withdrawal will not make earlier lawful use unlawful.

It may not be possible to recall:

• printed materials;
• archived publications;
• recordings already supplied to customers;
• press coverage;
• content shared by third parties; or
• materials already placed into public circulation.

We will take reasonable steps to prevent new use under our control after consent has been withdrawn.

Identifying Children

We will avoid publishing unnecessary identifying information alongside images of children.

Where appropriate for competition reporting or recognition, we may publish limited information such as:

• participant name;
• studio;
• routine title;
• age category;
• result; or
• award.

We will not publish a child’s private address, personal telephone number, personal email address or medical information.

13. Competition Results, Rankings and Awards

We may publish limited competition information, including:

• participant name;
• studio name;
• category;
• age division;
• routine title;
• score;
• placement;
• title;
• award; and
• scholarship result.

This information may be displayed:

• during an awards presentation;
• on event screens;
• in printed programmes;
• on leaderboards;
• on our website;
• on social media;
• in press information; and
• in historical competition records.

We publish this information to administer a transparent competition, provide results and recognise achievements.

14. Marketing Communications

We may send information about:

• competitions;
• workshops;
• training programmes;
• productions;
• tickets;
• opportunities;
• information packs;
• offers; and
• related services.

Marketing may be sent through:

• email;
• SMS;
• WhatsApp;
• telephone;
• post;
• social media; or
• online advertising.

We will only send electronic marketing where permitted by applicable data-protection and electronic-communications law.

Where consent is required:

• consent will be requested clearly;
• marketing choices will be separate from general terms;
• consent will not be assumed because somebody has read this policy;
• consent will not normally be required as a condition of purchasing an unrelated service; and
• consent may be withdrawn at any time.

Where legally permitted, we may contact existing customers about similar products or services. A clear opt-out will be provided.

You can stop marketing by:

• selecting the unsubscribe option in an email;
• replying to the message;
• changing your preferences where available; or
• using our contact form.

Opting out of marketing will not stop essential communications about:

• an active booking;
• an event;
• a payment;
• a cancellation;
• safety;
• safeguarding; or
• another contractual matter.

We may retain limited suppression information to ensure that an opt-out continues to be respected.

We do not sell personal data for another organisation’s independent marketing.

15. Cookies and Website Tracking

Our website may use:

• cookies;
• pixels;
• analytics;
• local storage;
• advertising technologies; and
• similar tools.

These may be used to:

• operate the website;
• remember settings;
• maintain security;
• process forms;
• measure performance;
• understand website use;
• assess marketing campaigns; and
• deliver relevant advertising.

Technologies that are strictly necessary may be used without consent where permitted.

Non-essential cookies and tracking technologies will be controlled through our cookie preference system where consent is required.

More information should be provided in our separate Cookie Policy.

16. Who We Share Personal Data With

We may share personal data where necessary with:

Event and Service Providers

• theatres and venues;
• judges;
• teachers and workshop leaders;
• presenters;
• production teams;
• event staff;
• authorised volunteers;
• chaperones;
• photographers;
• videographers;
• livestream providers;
• security providers;
• first-aid providers; and
• event partners.

Technology and Administration Providers

• website hosts;
• cloud-storage providers;
• registration systems;
• competition-management platforms;
• ticketing providers;
• payment providers;
• email and communication platforms;
• customer relationship management providers;
• accounting systems;
• analytics providers;
• IT support providers; and
• cybersecurity providers.

Professional and Regulatory Recipients

• accountants;
• auditors;
• solicitors;
• insurers;
• banks;
• tax authorities;
• regulators;
• courts;
• police;
• safeguarding authorities;
• local authorities;
• licensing authorities;
• medical services; and
• emergency services.

Business Reorganisation

Personal data may be disclosed in connection with a proposed or completed:

• business sale;
• merger;
• restructuring;
• investment;
• transfer of assets; or
• insolvency process.

Where a provider processes information on our behalf, we require appropriate confidentiality, data-protection and security obligations.

We only share information that is reasonably necessary for the relevant purpose.

17. International Transfers

Some of our technology, communication, payment and cloud providers may process personal data outside the United Kingdom or European Economic Area.

Where a restricted international transfer takes place, we will use an appropriate legal safeguard where required, such as:

• a UK adequacy regulation;
• an EU adequacy decision;
• approved contractual clauses;
• the UK International Data Transfer Agreement;
• the UK Addendum to approved contractual clauses;
• an approved international data framework;
• binding corporate rules; or
• another legally permitted safeguard or exception.

Where appropriate, we will assess whether additional contractual, organisational or technical protections are required.

Further information about relevant safeguards may be requested using the contact details in this policy.

18. How Long We Retain Personal Data

We retain personal data only for as long as reasonably necessary.

The following periods describe our normal approach.

Longer retention may be necessary where:

• the information concerns a child;
• a safeguarding matter exists;
• an accident or complaint occurred;
• a legal claim is anticipated;
• an insurer requires retention;
• a legal obligation applies; or
• the information forms part of an appropriate historical record.

When personal data is no longer required, it will be securely deleted, destroyed or anonymised.

Deletion from live systems may not immediately remove information from encrypted backups. Backup data will remain protected and will be deleted or overwritten through the normal backup cycle.

19. Data Security

We use proportionate technical and organisational safeguards designed to protect personal data.

These may include:

• password protection;
• multi-factor authentication;
• encryption;
• restricted permissions;
• access controls;
• secure cloud storage;
• device security;
• confidentiality obligations;
• secure payment systems;
• staff and contractor training;
• backups;
• software updates;
• security monitoring; and
• incident-response procedures.

Access is limited to people who reasonably require the information for their role.

No online system can be guaranteed to be completely secure. However, we take reasonable and proportionate steps to protect the personal data under our control.

20. Personal Data Breaches

Where a personal data breach occurs, we will:

• investigate the incident;
• take steps to contain it;
• assess the possible effect on individuals;
• record the incident;
• take appropriate remedial action;
• notify a supervisory authority where legally required; and
• notify affected individuals where the applicable legal threshold is met.

Not every security incident is a reportable personal data breach. Notification decisions will be made in accordance with applicable law.

21. Your Rights

Depending on the circumstances, you may have the right to:

Be Informed

Receive clear information about how your personal data is used.

Access Your Information

Request confirmation that we process your personal data and obtain a copy of relevant information.

Correct Your Information

Ask us to correct inaccurate or incomplete information.

Request Deletion

Ask us to erase personal data in certain circumstances.

The right to deletion is not absolute. We may need to retain information for:

• legal obligations;
• safeguarding;
• financial records;
• legal claims;
• freedom of expression;
• public-interest purposes; or
• another lawful reason.

Restrict Processing

Ask us to limit how personal data is used in certain circumstances.

Object to Processing

Object to processing based on legitimate interests.

You have an absolute right to object to direct marketing.

Data Portability

In certain circumstances, receive information you provided in a structured, commonly used and machine-readable format.

Withdraw Consent

Withdraw consent at any time where processing is based on consent.

Withdrawal will not affect processing that was lawful before consent was withdrawn.

Automated Decision-Making

Request appropriate safeguards where a legally or similarly significant decision is made solely through automated processing.

We do not currently use solely automated decision-making that produces legal or similarly significant effects concerning customers or participants.

22. How to Exercise Your Rights

Requests may be submitted:

Online: Contact form

By post:

The Aaron Dwyer Company

167–169 Great Portland Street

5th Floor

London

W1W 5PF

Please provide enough information to help us:

• understand the request;
• locate the relevant personal data; and
• confirm your identity where reasonably necessary.

We will not ordinarily charge a fee.

A reasonable fee may be permitted where a request is manifestly unfounded, excessive or repetitive, or where additional copies are requested.

We will respond without undue delay and within the period required by applicable law. This will normally be within one month after receiving the request and any information reasonably required to confirm identity.

The response period may be extended where legally permitted because a request is complex or multiple requests have been made. We will explain where an extension applies.

23. Data-Protection Complaints

You may complain if you believe that we have used personal data unfairly, unlawfully or inaccurately.

Complaints may be submitted:

Online: Contact form

By post:

The Aaron Dwyer Company

167–169 Great Portland Street

5th Floor

London

W1W 5PF

Please provide:

• your name and contact details;
• the nature of your concern;
• relevant dates;
• the personal data or activity involved;
• supporting correspondence or evidence; and
• the outcome you are seeking.

We will:

• provide an accessible method for making a complaint;
• acknowledge receipt within 30 days;
• make appropriate enquiries without undue delay;
• keep you reasonably informed;
• take appropriate steps to address the complaint; and
• explain the outcome without undue delay.

You also have the right to complain to a supervisory authority.

United Kingdom

The relevant supervisory authority is the Information Commissioner’s Office.

Republic of Ireland

The relevant supervisory authority is the Data Protection Commission.

You may also contact the supervisory authority in the country where you live, work or believe a data-protection infringement occurred.

We would appreciate the opportunity to address your concern directly, but contacting us first does not remove your right to approach a supervisory authority.

24. Third-Party Websites and Platforms

Our communications may link to:

• payment providers;
• ticket platforms;
• registration systems;
• competition platforms;
• social media;
• venues; and
• other third-party websites.

Those organisations may process information as separate data controllers under their own privacy policies.

We are not responsible for the privacy or security practices of independently operated third-party services.

25. Social Media

When you interact with us through a social media platform, both we and the platform may process personal data.

The platform may independently use information for:

• advertising;
• analytics;
• profiling;
• security; and
• personalisation.

The platform’s use of information is governed by its own terms and privacy information.

26. Keeping Information Accurate

Please contact us where:

• your contact information changes;
• participant information is incorrect;
• emergency or medical information changes;
• a person is no longer authorised to represent a studio;
• your marketing preference changes; or
• previously supplied information is no longer accurate.

Studios and organisers must check information before submitting an entry and notify us promptly of corrections.

27. Changes to This Policy

We may update this policy to reflect:

• changes to our services;
• new technology;
• changes in suppliers;
• changes to our events;
• legal developments;
• regulatory guidance; or
• changes to how personal data is processed.

The updated policy will be published on our website with a revised “last updated” date.

Where a change materially affects how personal data is used, we may provide additional notice through email, our website, an account or another appropriate channel.

28. Contact Details

Questions, rights requests and complaints should be directed to:

The Aaron Dwyer Company

167–169 Great Portland Street

5th Floor

London

W1W 5PF

Online: Contact form

Telephone: +44 (0)7375 947708