This Privacy Policy explains how RAJCLOTH CONNECTIONS LIMITED (“we”, “us” or “our”) collects, uses and protects personal information when you visit amolrajanconnection.com (the “Website”), subscribe to the Amol Rajan Connection newsletter, create an account, join or participate in the Amol Rajan Connection Club (the “Club”), use Club community features, attend or participate in Club events, livestreams or recordings, contact us, or use Club-related ticketing, event and merchandise benefits.RAJCLOTH CONNECTIONS LIMITED is a company registered in England and Wales under company number 11721998.

Our registered office is 15-17 Church Street, Stourbridge, West Midlands, United Kingdom, DY8 1LU.For the purposes of UK data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018, we are the controller of the personal information described in this Privacy Policy. We use service providers to process personal information on our behalf where necessary.

Other providers may process personal information as independent controllers for their own purposes, as explained below.In some circumstances, the respective roles of the parties may depend on the particular event, feature or processing activity. Where we and another organisation jointly determine how and why particular personal information is used, we will provide any additional information required about that arrangement.

You can contact us about privacy matters at:

• Email: [email protected]

• Post: RAJCLOTH CONNECTIONS LIMITED, 15-17 Church Street, Stourbridge, West Midlands, United Kingdom, DY8 1LU

3.1 Information you provide to us

• Account and membership information: your name, account identifiers and authentication information, such as your email address and information used to maintain or verify access. We do not receive your password where it is set and controlled directly through a platform provider. We also collect membership tier, subscription status, account and communication preferences and, where you apply for a student membership or discount, information reasonably required to verify your eligibility, such as your educational institution, expected graduation date or other evidence of current student status. We will tell you what evidence is required, who carries out the verification and whether the provider acts on our instructions or under its own privacy notice. Where possible, we will record only the verification outcome and any necessary audit information rather than retaining a copy of the underlying document.

• Newsletter information: your email address and preferences when you subscribe to our newsletter or other communications.

• Payment and transaction information: membership purchases, subscription amounts, payment status, renewals, cancellations, refunds, billing address, transaction identifiers, receipts and transaction history. Payment-card information is collected and processed by our payment provider. We do not receive or store full payment-card numbers or card security codes.

• Customer-support information: communications, queries, feedback, complaints and information you provide when contacting us.

• Business and contributor information: names, roles, contact details, professional information and correspondence relating to speakers, guests, contributors, sponsors, suppliers, advisers, prospective commercial partners and other business contacts.

• Community information: your display name, profile information, posts, comments, reactions and interactions where you use Club community features, together with member reports, moderation communications, moderation decisions, warnings, suspensions and other records relating to compliance with the Club Membership Terms or community rules.

• Member submissions and participation information: questions submitted for “Ask Me Anything” sessions, survey responses, competition or prize-draw entries, suggestions, testimonials and other content or information you choose to submit to us.

• Event information: information needed to administer Club event benefits, including membership eligibility, ticket-priority status, ARC Live ticket allocation and communications about events.

• Event and content participation information: your name, contact details, membership status, questions or other contributions you submit, and your image, voice, appearance and participation where you choose to take part in a livestream, recording, interview, event, audience contribution or other Club content. Where an event or production involves recording, publication or uses that are not reasonably apparent from this Privacy Policy, we will provide additional information at the relevant time and obtain any consent, release or other permission required for that activity.

• Public-recognition choices: your chosen display name and opt-in preference if your membership tier includes the option to appear in show credits or in the Patrons and Partners section of the Website. If you choose to be publicly recognised, the name you select may be visible to the general public and may be indexed, copied or republished by third parties. You can ask us to stop using your name in future editions or displays, but we may not be able to remove it from material already published or distributed.

• Merchandise eligibility information: limited information necessary to verify eligibility for a Club merchandise discount.Where we ask you to provide information needed to create an account, enter into or perform a membership contract, process payment or verify eligibility for a particular tier or benefit, you may not be able to create the account, purchase the membership or receive the relevant benefit if you do not provide that information.

  3.2 Special category information and information handled by event providers
  

  Certain personal information is more sensitive and receives additional protection under data protection law. For example, accessibility or dietary information may reveal information about a person’s health or religious beliefs.

  Event ticketing, attendance, accessibility and dietary information will usually be collected directly by the relevant event or ticketing provider under its own privacy notice and terms. Where possible, you should provide accessibility and dietary requirements to that provider through its booking process.

  We may nevertheless receive or process limited accessibility, dietary, health, religious or other sensitive information where you provide it directly to us or where, with an appropriate legal basis, an event provider needs to share it with us so that we can make the requested arrangements. Where this information constitutes special category personal information, we will generally process it with your explicit consent. In limited circumstances, we may also process it where necessary to protect someone’s vital interests when they are incapable of giving consent, or to establish, exercise or defend legal claims. Where we rely on explicit consent, you may withdraw it at any time. Withdrawal will not affect processing already carried out lawfully, but it may affect our ability to make the requested arrangement.

  Please avoid including unnecessary health or other sensitive personal information in public or community posts. Community posts may be visible to other members in accordance with the functionality of the relevant community platform.

  3.3 Information collected automatically

  When you use the Website, newsletter or Club, we may collect, or receive from providers operating the Website, newsletter, account and Club services on our behalf:

• Your IP address, device type, operating system, browser type and browser settings.

• Pages visited, content viewed, links clicked, the date and time of visits, referring URL and approximate location derived from your IP address.

• Information about email delivery and engagement, such as whether an email has been opened or a link selected.

• Information about your access to Club content, subscription status and use of community features.

• Login dates and times, account authentication information, failed-login attempts, security events and activity relevant to preventing fraud, misuse or unauthorised access.

• Cookie, pixel, local-storage and similar-technology identifiers. We obtain consent before using non-essential cookies or similar technologies where required. Essential technologies may be used without consent where they are strictly necessary to provide a service you have requested or for other purposes permitted by law.

  3.4 Information we receive from third parties

  We may receive:

• account, subscription, membership, community and engagement information from beehiiv;

• payment status, transaction references, billing information, subscription status, refunds and fraud indicators from Stripe;

• membership-discount or merchandise-enquiry information from Teemill where needed to resolve an eligibility or support issue;

• ticket-entitlement, booking-status, attendance or event-administration information from Fane and other ticketing or event partners where needed to administer a Club benefit or respond to an enquiry;

• technical, security and diagnostic information from our hosting, security and technology providers;

• information from fraud-prevention, identity or eligibility-verification providers, or from public sources that it is reasonable and lawful for us to use, where necessary to verify information, protect the Club or investigate suspected fraud, misuse or threats to safety. This may include identity, contact, eligibility or fraud-risk information. We will not carry out general or unrelated background checks on members. Where student status is checked through a verification provider, we will normally receive confirmation of whether the eligibility criteria have been met and limited information needed to investigate an unsuccessful or disputed verification. The provider used and any additional information relevant to the verification will be identified during the application process; and

• information about your interactions with content or functionality embedded in or loaded through the Website, subject to your cookie choices where applicable.

  Where we obtain your personal information from another source rather than directly from you, we will provide or otherwise make available the information required by data protection law within the applicable period, unless an exception applies.

We use your personal information for the following purposes.

●      Creating and administering your account and providing Club benefits. Legal basis: necessary to perform our contract with you, or to take steps at your request before entering into a contract.
●      Providing newsletters and editorial communications that you have requested. Legal basis: your consent where you subscribe separately to a free newsletter; and performance of our contract where a communication forms part of the content or service included in your membership.
●      Processing payments and managing subscriptions, renewals, cancellations, refunds and receipts. Legal basis: necessary to perform our contract with you; necessary to comply with legal obligations.
●      Verifying eligibility for priority booking, administering ARC Live ticket entitlements and communicating about Club events. Legal basis: necessary to perform our contract with the member where we use information to provide the purchased benefit; and our legitimate interests in preventing misuse, maintaining accurate eligibility records and administering events where that processing is not necessary for the contract.
●      Verifying eligibility for a student membership or discounted student rate. Legal basis: necessary to take steps at your request before entering into a contract and to perform our contract with you; and our legitimate interests in preventing misuse of eligibility-based rates.
●      Managing member participation, questions, surveys, competitions, prize draws, feedback and other Club activities. Legal basis: performance of our contract where the activity is a Club benefit; performance of applicable competition or prize-draw terms; our legitimate interests in operating and improving the Club and encouraging member participation; and consent where required.
●      Administering and producing Club events, livestreams, recordings and other content, including selecting and communicating with participants and publishing content in which a member has agreed to participate. Legal basis: performance of our contract where participation itself forms part of a Club benefit; our legitimate interests in selecting participants and producing, operating and promoting the Club and its content where those interests are not overridden by the individual’s rights; consent where we have told you that a particular optional use depends on consent; and performance of a separate participant release or agreement where applicable. We will provide additional information at the relevant time where the intended recording, publication or promotional use would not reasonably be apparent from this Policy.
●      Enabling access to the merchandise store and applying member discounts. Legal basis: necessary to perform our contract with you and, where applicable, our legitimate interests in administering Club benefits.
●      Responding to queries, complaints and support requests. Legal basis: necessary to perform our contract with you; our legitimate interests in operating and improving our services.
●      Managing contributors, suppliers, commercial relationships and prospective partnerships. Legal basis: our legitimate interests in operating, producing, developing and promoting the Website, Club, newsletters, content and events; taking steps to enter into or perform a contract; and compliance with legal obligations where applicable.
●      Operating, moderating and protecting community features. Legal basis: our legitimate interests in maintaining a safe and functional community and enforcing the Club Membership Terms.
●      Understanding and improving the Website, Club and newsletter, including measuring engagement and performance. Legal basis: consent where we use cookies or similar technologies requiring consent; otherwise our legitimate interests in understanding, securing and improving our services where that processing is permitted without consent.
●      Sending service messages, including renewal reminders, payment notices, changes to the service, security messages and legal notices. Legal basis: necessary to perform our contract with you; our legitimate interests in operating the service.
●      Sending promotional marketing about our own related products, content, memberships, events and merchandise through email or other channels you have selected. Legal basis: your consent or, for electronic marketing to an existing customer, the customer soft opt-in where its statutory conditions are satisfied. Where we rely on the soft opt-in, the marketing will concern our own similar products or services, we will have obtained your contact details in connection with a sale or negotiations for a sale, and we will provide a clear opportunity to opt out when collecting the details and in every subsequent message.
●      Preventing, detecting and investigating fraud, misuse, security incidents and unlawful activity. Legal basis: our legitimate interests in protecting our business, members, services and systems; and compliance with legal obligations where applicable.
●      Providing optional public recognition and member acknowledgements. Legal basis: your consent. You may withdraw that consent for future use at any time, although this will not necessarily affect material already published or distributed.
●      Meeting tax, accounting, regulatory and other legal obligations. Legal basis: necessary to comply with legal obligations.
●      Establishing, exercising or defending legal claims and protecting our legal rights. Legal basis: our legitimate interests in protecting our business and enforcing our rights; compliance with legal obligations where applicable.

Where we rely on legitimate interests, we consider your rights and interests and use your information only where our interests are not overridden by your privacy rights.

When you subscribe to the free newsletter, we send you the editorial newsletter you have requested. You can withdraw from the newsletter at any time by using the unsubscribe link or contacting us.Where permitted by electronic marketing law, we may send existing customers marketing by email about our own similar products or services if we obtained their contact details in connection with a sale or negotiations for a sale, gave them a clear opportunity to opt out when collecting the details and provide an opt-out in every subsequent message.

You can join the Club without agreeing to receive separate promotional marketing. Declining promotional marketing will not affect your membership or your entitlement to receive service communications or membership content forming part of the service you have purchased.

Some emails may use technologies which provide information about delivery, opening or interaction. Where consent is required for such a technology, we will obtain it before using it. Depending on the technology and email service, you may also be able to limit email tracking through your email settings or preference tools we make available.You may withdraw marketing consent at any time by using the unsubscribe link in a message, by changing your preferences in the link or account area we provide, or by contacting [email protected].

Withdrawing consent does not affect the lawfulness of marketing sent before your request. We keep limited information on a suppression list so that we respect your choice.Separately from marketing, we send service communications that are necessary for your account or membership, such as purchase confirmations, payment receipts, renewal reminders, changes to the Club, security alerts, legal notices and other important administrative information.

We treat these as service communications rather than promotional marketing where their content is limited to information reasonably necessary to administer the relevant account, membership or service. If a communication also contains promotional marketing, we will apply the relevant marketing rules to that content. We need to send service communications where they are necessary to administer your account or membership, comply with law, protect security or provide important information about the service. If you do not wish to receive account or membership communications, you may need to close your account or end your membership.

We may share your personal information with:

● beehiiv, to host and deliver newsletters, operate membership features and support community functionality, and to provide analytics about newsletter and Website engagement.
● Stripe, which processes membership payments, recurring charges and refunds and provides payment, transaction and fraud-prevention information. Stripe’s role in relation to particular processing is described in its own privacy information and our payment arrangements.
● Teemill, which is the merchant of record for merchandise purchases. Teemill operates the merchandise storefront and processes the personal information needed to take payment, fulfil orders, arrange delivery, provide customer support and manage returns and other merchandise enquiries. This may include your name, contact details, delivery address, order details, payment information and communications. Teemill processes that information as an independent controller under its own privacy notice and terms.
● Fane and other ticketing or event partners, to administer live events. We share only the limited information needed to verify eligibility and administer entitlements, such as your name, email address, membership tier and eligibility for priority booking or an ARC Live ticket. Fane and other ticketing or event partners may act as independent controllers for ticket purchases, attendance, accessibility, dietary requirements and their own event administration, as explained in their respective privacy notices and terms.
● Student-status verification providers, to assess eligibility for a student membership or discount and help resolve unsuccessful or disputed verifications.
● Other Club members, where you create a profile, post, comment, react or otherwise participate in community features. The information visible to other members will depend on the functionality of the community platform and the information you choose to share.
● Website hosting, technical support, security, email and communications providers.
● Professional advisers, including lawyers, accountants, auditors and insurers.
● Companies, personnel and contractors involved in operating or producing the Website, Club, newsletters, content and events, subject to appropriate confidentiality and data protection obligations.
● Regulators, law-enforcement agencies, courts or other authorities, where required by law or necessary to protect rights, property or safety.
● Buyers, investors or their advisers in connection with a proposed or completed merger, financing, reorganisation, asset sale or other business transfer.
● Video, social media and other content-platform providers where you view or interact with content embedded in or loaded through the Website, subject to your cookie choices where applicable.

Some organisations receiving your personal information act as our processors and handle it on our instructions. Others, including certain payment, merchandise, ticketing and event providers, may act as independent controllers for the services they provide directly to you. Where another organisation acts as an independent controller, you may need to exercise your rights directly with it under its own privacy notice. Contact us if you are unsure and we will try to assist or direct your request appropriately.

Some of the providers we use, or their group companies and subprocessors, may process personal information outside the United Kingdom, including in the United States.Where we make a restricted transfer of personal information, we use a transfer mechanism permitted by UK data protection law.

Depending on the destination and recipient, this may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU standard contractual clauses, or another permitted safeguard or derogation.

Where required, we assess the laws and practices of the destination country and implement supplementary contractual, technical or organisational measures.The mechanism used depends on the recipient, destination and circumstances of the transfer.

Contact us if you would like information about the mechanism relevant to your information and how to obtain a copy of the applicable safeguards, subject to appropriate redactions.

We keep personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Website and Club, meet legal, tax, accounting and reporting obligations, resolve disputes, enforce our agreements and protect our rights.

Where no fixed period is stated, we determine retention by considering the nature and sensitivity of the information, the purpose for which it is used, contractual and legal requirements, relevant limitation periods, and the risk of harm from unauthorised use or disclosure.

In general:

• we retain account and membership information while your account or membership remains active and for a reasonable period afterwards;

• payment, invoice, refund and tax records are retained for the periods required by applicable tax and accounting law;

• newsletter and marketing information is retained until you unsubscribe or withdraw consent, after which we retain limited suppression information so that we can respect your choice;

• support, complaint and moderation records are retained for as long as reasonably necessary to resolve the matter, protect users and establish or defend legal claims;

• student eligibility evidence is retained only for as long as needed to verify eligibility and, where possible, we retain the verification result rather than the underlying evidence;

• security logs and technical information are retained for a limited period unless they are required to investigate an incident; and

• recordings, photographs and published content may be retained for as long as the relevant material continues to be used for the purpose explained when it was collected, forms part of our published editorial archive, or must be retained under an applicable agreement or legal requirement. We will periodically review unpublished recordings and production material and delete or anonymise it when it is no longer reasonably required. Any continued promotional use will remain subject to the applicable legal basis and any relevant consent or release.

  Closing your account or ending your membership does not necessarily result in the immediate deletion of all associated information. We may retain information where required for accounting, fraud prevention, dispute resolution, legal claims, suppression records, moderation history or other lawful purposes.

We use cookies and similar technologies, including tags, local storage and analytics technologies, to operate the Website, remember your preferences, keep the Website secure and measure performance.

Further information is available in our Cookie Policy.

Where the Website provides a cookie-control tool, you can use it to change your choices or withdraw consent. You may also be able to control cookies through your browser.

Further information is provided in our Cookie Policy.

We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful loss, destruction, alteration, unauthorised disclosure or access. No internet transmission or electronic storage system is completely secure.

Please keep your account credentials confidential and contact us promptly if you believe your account has been accessed without permission.

Depending on the circumstances and subject to the conditions and exemptions in data protection law, you may have the right to:

● Ask for access to the personal information we hold about you.
● Ask us to correct inaccurate or incomplete personal information.
● Ask us to delete your personal information in certain circumstances.
● Ask us to restrict our processing in certain circumstances.
● Object to processing based on our legitimate interests, and to object to direct marketing at any time.
● Withdraw your consent where we rely on consent.
● Ask for data portability where applicable.
● Not to be subject to certain decisions based solely on automated processing that produce legal or similarly significant effects, where applicable.
● Make a complaint to us about the way we have processed your personal information.

To exercise your rights, contact [email protected]. Where an independent controller such as Stripe, Teemill or Fane processes your information under its own privacy notice, you may need to exercise your rights directly with that provider. Contact us if you are unsure and we will try to direct you.

Based on the services and processes currently used by us, we do not make decisions about members based solely on automated processing where those decisions produce legal or similarly significant effects. Payment, fraud-prevention, eligibility or platform providers may use automated tools for their own purposes, as explained in their privacy information. If we begin making such decisions ourselves, we will provide the information required by law about the decision, its likely consequences and the safeguards available to you.

We may need to verify your identity before responding. We will normally respond within one month of receiving your request. Where a request is complex, or where you have made a number of requests, we may extend that period as the law allows, and we will tell you if we need to do so and why. You may also make a data protection complaint to us or to the Information Commissioner’s Office, as explained in section 12.

You may complain to us if you believe that we have not handled your personal information in accordance with data protection law. You can make a complaint by emailing [email protected] or writing to the postal address in section 2. Please describe the issue and, where possible, the outcome you are seeking.

We will acknowledge receipt of your complaint within 30 days. Without undue delay, we will take appropriate steps to respond to the complaint, including making appropriate enquiries. We will keep you informed if our investigation is continuing and will tell you the outcome without undue delay.

You also have the right to complain to the Information Commissioner’s Office. Details are available at ico.org.uk. You may complain to the Information Commissioner’s Office at any time, although we would welcome the opportunity to address your concerns first.

Paid Club membership, paid membership accounts and Club community features are available only to adults aged 18 or over. The free newsletter is available to people aged 13 or over. Public areas of the Website may be browsed without creating an account, subject to the Website Terms.If you are aged 13 to 17, this Privacy Policy applies to information we collect when you subscribe to the free newsletter or otherwise interact with the public Website. We encourage you to read it with a parent or guardian. Paid membership, paid membership accounts and community features are not offered to people under 18.

The free newsletter is not offered to children under 13. Paid membership, paid membership accounts and community features are not offered to anyone under 18. We do not knowingly collect personal information from children under 13 through the newsletter or account services.

If you believe that a child under 13 has provided personal information to us, please contact [email protected]. We will investigate and take appropriate steps, which may include deleting the information.

The Website may link to or embed content from third-party websites, apps and services, including YouTube, Teemill for merchandise and Fane for event ticketing. Those services are operated independently and we are not responsible for their privacy practices. Please read their privacy notices before providing them with personal information.

We may update this Privacy Policy from time to time to reflect changes to our services, suppliers, legal obligations or data-handling practices. We will publish the revised version on the Website and change the “Last updated” date.

Where a change is material, we will take reasonable steps to bring it to your attention, for example by email, through your account or by displaying a prominent notice on the Website. Where required, we will ask for your consent before using personal information for a materially different purpose.