Brighter Events (“Clarity" / 'We”) are committed to protecting and respecting your privacy. Brighter Events are committed to respecting and protecting your privacy whilst remaining compliant with the EU General Data Protection Regulation (GDPR) and the Data Protection Act (DPA). In line with this objective we operate an Information Security Management System which is certified against ISO 27001:2013 and a Personal Information Management System aligned with the BS 10012:2017 standard.

Clarity Travel Limited (as Brighter, hereafter referred to as such) are a Data Processor and have appointed a Data Protection Officer who can be contacted as follows: DPO@claritybt.com

You can also contact Clarity by post, c/o IT Compliance, at 4th Floor, Churchgate House, 56 Oxford Street, Manchester M1 6EU. 

We may collect and process the following data about you:

Information that you provide in order to make an event booking (see below*) or purchase any other services via Brighter; Details of transactions you carry out through Brighter, and of the fulfilment of your bookings;
Details of your visits to Brighter (including, but not limited to, traffic data and location data), whether this is required for our own purposes or otherwise, and the resources that you access; Information you provide in order to enter a competition or promotion, complete a survey, or if you report a problem with Brighter.

*In terms of personal information collected during the event booking process, this may include traveller name, gender, date of birth, residential address, email address, passport details, next of kin information and employer details, as well as dietary requirements, details of any disabilities and even loyalty card information if the booker wishes to share this information. This is not a default list, however and should not be considered a baseline dataset. 

If you contact us, we may keep a record of your email or other correspondence.

We’re based in the UK but sometimes your personal information may be transferred outside the European Economic Area (EEA). If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply. You can review a list of our sub-processors by visiting:

www.claritybusinesstravel.com/sub-processors

In order to fulfil global event management some personal information may ultimately be sent to non-EEA locations by downstream travel service providers, for example airlines or hotels. We treat these third parties as Data Controllers and as such cannot be accountable for the way in which they process data.

To fulfil its contractual and customer obligations, there is a requirement for Brighter to collect and process specific, personally-identifiable information relating to our clients’ employees and representatives. Our legal basis for processing is that to do so is necessary for the performance of a contract to which you are party. We may use information held about you in the following ways:

- To provide event management services;
- To carry out our obligations arising in connection with any contracts entered into between you and us, or between you and a third party;
- To notify you about changes to our service;
- To provide you with information and offers that we, or selected third parties, feel may interest you. If you are an existing customer, we will only contact you by electronic means with information about services similar to those which were the subject of a previous sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.

We do not carry out any automated decision-making or profiling based on personal data which has been collected.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties
Other companies in the Mawasem Limited Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.

• External Third Parties
i. Suppliers of travel services acting as processors based in the country to which you are travelling and who provide the travel services that make up any booking of travel services that you make with us.

ii. Service providers acting as processors based in the European Union who provide IT and system administration services.

iii. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union who provide consultancy, banking, legal, insurance and accounting services.

iv. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

v. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

YOUR LEGAL RIGHTS

You have the right to:

• Request access
to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

• Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us via the details below:

Contact details

Our full details are:

Full name of legal entity: Mawasem Limited trading as Clarity
Name or title of DPO: Lois Haynes
Email address: DPO@claritybt.com
Postal address: Clarity, c/o IT Compliance, 4th Floor, Churchgate House, 56 Oxford Street, Manchester M1 6EU

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy. For further detail please contact us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

We use different methods to collect data from and about you including through:

(A) Direct interactions

You may give us your identity, contact and financial data and special categories of personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• make a booking of event services;
• query an existing event booking;
• create an account on our website;
• subscribe to our newsletter, or other publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us some feedback;
• offer your services to us as a supplier.

(B) Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

(C) Third parties

We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:

(i) analytics providers such as Google based outside the EU

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you;
• To make bookings of event services on your behalf and at your request;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to processing Special Categories of Personal Data and sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data. 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. The following sections provide further explanation as to how we seek to do this.

Promotional offers from us

We may use your identity, contact, technical, usage and traveller profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third-party company for the purposes of that company sending you marketing material.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.

Monitoring communications

We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy. For further detail please contact us.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure in the Glossary for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

LAWFUL BASIS

• Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

• Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

• Internal Third Parties
Other companies in the Mawasem Limited Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting.

• External Third Parties
i. Suppliers of travel services acting as processors based in the country to which you are travelling and who provide the travel services that make up any booking of travel services that you make with us.

ii. Service providers acting as processors based in the European Union who provide IT and system administration services.

iii. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union who provide consultancy, banking, legal, insurance and accounting services.

iv. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

• Request access
to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 

• Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.