1. Introduction
At Art Culture Tourism we are committed to ensuring that your personal information is protected and you understand how it is used. This Privacy Notice explains what personal information we collect, why we collect it, how we use it, the controls you have over your personal information and the procedures that we have in place to protect your personal information. It applies to the personal information we collect when an individual visits our Website (<your company website>).

In this Privacy Notice, when we refer to "Art Culture Tourism", "us", "we" or "our", we mean the Art Culture Tourism group company or Art Culture Tourism companies which are responsible for any personal information collected about you, and the Art Culture Tourism companies to which you may apply.

2. Principles of Data Protection
When using the term “personal data” or “personal information” in this Privacy Notice, we mean information (including opinions) that relates to you and from which you could be identified, either directly or in combination with other information which we may have in our possession.

We will treat your data with respect and in line with the regulation. We will ensure that your data is:

· Used lawfully, fairly and in a transparent way.
· Collected only for lawful purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
· Relevant to the purposes we have told you about and limited only to those purposes.
· Accurate and kept up to date.
· Kept only as long as necessary for the purposes we have told you about.
· Kept securely and protected.

Our site may provide links to third party websites. Art Culture Tourism is not responsible for the conduct of non-Art Culture Tourism companies linked to the site and you should refer to the privacy notices of these third parties as to how they may handle your personal information.

3. Sources of Personal Data
We collect personal data about you from a variety of sources, as follows:
· The personal data is provided to us by you via your parents or your school teacher who will register your submission through our website.
· The personal data is collected in the normal running of our relationship with you (e.g. when you submit an enquiry to us).
· The personal data has been made public by you (e.g. contacting Art Culture Tourism via a social media platform).
· Your personal data is collected when you visit our Website or use any features or resources available on or through the Website, some of which may be personal data.
· The personal data may be created by us, such as records of your communications with us.

4. Personal Data Collected
The following is a summary of the types of personal data we collect on our Website portal:
· Personal and contact details: name, surname, or name of school or group, city of residence, country.
· Consents: consents, permissions, or preferences that you have specified, such as whether you wish to subscribe to receive Art Culture Tourism announcements, updates, exhibitions, events, promotions.
· Website Access Details: your computers unique identifier (e.g. IP Address), the date and time you accessed the Website

5. Purposes and Use of Personal Data
The main purposes for using your personal information are (where applicable):-
· to support and progress your submission for the purpose of the exhibition
· to improve and monitor the operation of our Website.

We use information held about you in the following ways:-
· to inform you of similar exhibition arising at Art Culture Tourism in the future.
· to administer our website and for internal operational purposes to make user experience more efficient (including troubleshooting) and to analyse how the systems are used.
· to enable you to participate in interactive features within our website.
· to prevent unauthorised access and modifications to systems.

6. Legal basis for using your Personal Information
Data protection and privacy laws requires us to have a “legal basis” or “lawful ground” to collect and handle your personal information. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal justification to do this.

The following is a summary of the relevant legal bases for the purposes of the Privacy Notice:

· We need to use your personal information to register your submission for the purpose of the art exhibition
· Our use is necessary for the complying with our legal obligations;
· Where it is necessary for our legitimate interests (or those of a third party) as a commercial organisation
(to the extent that your interests and fundamental rights do not override those interests), such as:
· maintaining adequate applicant records;
· to assess suitability for a role including contacting references for verification purposes;
· to detect and protect against fraud;
· to make sure we are following our own internal procedures so we can deliver the best services
· delivering the requested news alerts or updates to you;
· establishing, exercising or defending our legal rights in the event of a claim;
· monitoring operational efficiency of the Website;
· managing and operating our website IT systems and ensuring security of those systems; and/or

7. Exemptions
Art Culture Tourism sometimes handles personal information relying on exemptions under the applicable data protection law. Any permitted handling of personal information under such exemptions will take priority over this Privacy Notice to the extent of any inconsistency.

8. Sharing Your Personal Information With Others
We will only disclose personal information to a third party in very limited circumstances, or where we are permitted to do so by law. The third parties to whom we provide your personal data include:
· Art Culture Tourism’s third party providers including information technology suppliers and infrastructure support services, law firms and our counterpart OKAY! Italy
· Government, regulatory and law enforcement bodies where we are required in order:
a) to comply with our legal obligations;
b) to exercise our legal rights (e.g. pursue or defend a claim); and
c) for the prevention, detection and investigation of crime.

We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale or transfer of assets, or changing services suppliers provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.

Less commonly, we may process and share your personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.

Art Culture Tourism will only share your personal data with our contracted service providers when we have established they have adequate and sufficient data protection controls and security controls in place (please also refer to section 9 below). We also implement contractual obligations on these third parties to ensure they can only use your data to provide services to Art Culture Tourism for the purposes listed above. The third parties cannot pass your details onto any other parties unless instructed to by Art Culture Tourism.

9. Transferring Your Personal Information Globally
We operate in collaboration with OKAY! Italy and consequently your personal data may be transferred and stored in the EEA (European Economy Area) which is subject to the EU General Data Protection Regulation.

We will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we are satisfied that alternative arrangements are in place to protect your privacy rights. To achieve this:

· we will, when transferring personal data to third parties outside the EEA:
  - include the standard contractual clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties; or
  - ensure that the country in which your personal information will be handled has been deemed "adequate" by the European Commission.
· we carefully validate any requests for information from law enforcement or regulators before disclosing the information.

We will always co-operate with any regulators as required by law to ensure that we remain transparent about the way we handle your personal information.

In any case, our transfer, storage and handling of your personal information will continue to be governed by this Privacy Notice. If you would like further information about the handling of your personal information, please contact us at artculturetourism@gmail.com

10. Security of Your Personal Information
Art Culture Tourism takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, modification, disclosure, alteration and destruction. We protect electronic data using a variety of security measures including:

· password access,
· data back-up,
· encryption,
· pseudonymisation
· placing confidentiality requirements on employees and service providers and providing training to ensure that your personal data is handled correctly.
· destroying or permanently anonymising personal information if it is no longer needed for the purposes it was collected

11. How long do we keep your personal information?
Art Culture Tourism will only retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice and as otherwise needed to comply with applicable law and internal company policies.

12. Your Legal Rights in Respect of Your Personal Information
You have legal rights in connection with personal information. Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Right to be forgotten enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it and we have no legitimate ground for retaining such information. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing.
• Object to processing of your personal information by us or on our behalf in certain situations.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please submit your requests in writing to artculturetourism@gmail.com

Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request.

13. Withdrawing Consent
If you have requested Art Culture Tourism to contact you regarding business alerts, regulatory updates or about future events/exhibitions, you may withdraw your consent to be contacted at any time. You can tell us that you no longer wish to be contacted by:

· Using the unsubscribe option included on email correspondence. · Sending us an email to artculturetourism@gmail.com

You also have the right to contact the Information Commissioner’s Office and file a complaint. (https://ico.org.uk/concerns/). The Information Commissioner’s Office will then investigate your complaint accordingly.

14. Changes to this Privacy Notice
We may amend this Privacy Notice from time to time to keep it up to date with legal requirement and the way we operate our business. This Privacy Notice was last reviewed and updated in Feb 2021

Please regularly check this page for the latest version of this Privacy Notice.