Last Updated: May 2018
For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the General Data Protection Regulation) and other applicable data protection legislation, the data controller of any personal data we collect from you, or that you provide to us, is Santa Claus, 1 North Pole, Earth (“SANTA”).
Information we collect about you:
We may collect and process your personal data, which we have obtained directly from you or from somewhere else with your approval (including but not limited to parents, guardians, other family relations, friends and teachers – together “Stakeholders”) if:
· you are a child (see further below for child aged under 13; and/or
· you believe in SANTA.
How we collect data about you:
Personal data collection methods we may use include:
· receipt of letters, emails, text messages, fax and any other form of physical or digital communication method;
· thoughts and wishes; and
· active and passive Elf-based remote monitoring.
What kind of personal data we process:
This may include:
· Identity data including first name, maiden name, last name, date of birth and gender;
· Contact data including postal address and email address;
· Your Naughty and Nice levels, including but not limited to: aggregated and anonymised examples of good and bad conduct in relation to people with whom you come into contact; the number of times in which you have made aforementioned Stakeholders and random people smile or cry; the amount of stray animals and/or children and/or random people you have helped in the preceding year; the aggregate number of mince pies and/or other appropriate sweet treats left out to SANTA in preceding years;
· Previous presents you have given and received at Christmas;
· Sensitive personal data including your state of health;
· How much you love SANTA;
· How Stakeholders feel about you; and
· How often you are awake or sleep on Christmas Eve.
How we use your information:
This may include:
· Provision of presents (including navigation to and entry into your home);
· Consumption of mince pies or other applicable sweet treats;
· Reindeer care;
· Spreading festive cheer; and
· For our legitimate commercial interests (including monitoring the performance of our services, ensuring our services are provided in the appropriate, and to notify you of changes to our services).
With whom do we share your information:
This may include:
· Members of the SANTA’s Grotto team including but not limited to elves, reindeer and Mrs Claus; and
· Appropriate third parties (including but not limited to the Easter Bunny and the Tooth Fairy).
How we store your information:
How long we retain your information:
We will only retain your personal data for as long as necessary to fulfil the purpose(s) we collected it for. To determine the appropriate retention period, we consider factors such as the amount, nature, sensitivity and purpose for processing your personal data as well as the duration of your belief in SANTA.
A quick word about children:
Protecting children's privacy is extremely important to SANTA. When users identify themselves as being children we will: (1) not provide a path for them to input personal information, (2) collect certain information for limited purposes only, and/or (3) obtain consent from parents for the use of their children's personal information, all according to applicable law. When we say children, we mean under the age of 13 or the minimum age in the relevant territory if that age is older than 13.
We encourage you to talk with your children about communicating with strangers and imposter SANTAs (including without limitation SANTAs found at shopping malls).
You have the right to opt out of our services at any time through provision of a ‘I DON’T BELIEVE IN SANTA’ or ‘I’VE BEEN NAUGHTY’ notice (available at www.santaclaus.com/notices) to firstname.lastname@example.org. You have the right to ask us not to process your personal information for marketing purposes. Depending on where you live, you may have additional privacy rights. For example, in the EU (particularly under the General Data Protection Regulation) you have the right to access and obtain a copy of your personal data we possess; you have the legal right to ask us to rectify/correct your personal data; and you may have the legal right to contact us to request that we delete your personal data from our system. We will use commercially reasonable efforts to honour your request, but we may decline requests that are unreasonably repetitive, disproportionate, infringe the privacy of others or as otherwise permitted by law or are naughty. Please note though that by withdrawing your consent or otherwise objecting to certain processing of your information, we may not be able to provide certain services to you or the services may not function correctly – this includes but is not limited to you receiving non-personalised presents at Christmas and may result in appropriate circumstances in cessation of delivery of presents by SANTA.
Changes and Contact: