Lochcarron Leisure Centre Ltd
Privacy Policy
Introduction
Welcome to Lochcarron
Leisure Centre’s privacy notice.
Lochcarron
Leisure Centre respects your privacy and is committed to protecting your
personal data. This privacy notice will inform you as to how we look after your
personal data and tell you about your privacy rights and how the law protects
you.
Please use the Glossary to
understand the meaning of some of the terms used in this privacy notice.
1. Important Information and who we are:
Purpose of this Privacy Notice
This
privacy notice aims to give you information on how Lochcarron Leisure Centre Ltd
collects and processes your personal data, including any data you may provide
through our website when you sign up to our newsletter, purchase our service
and/or product or take part in a competition.
This
website is not intended for children and we do not knowingly collect data relating
to children.
It is important that you read
this privacy notice together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or
processing personal data about you so that you are fully aware of how and why
we are using your data. This privacy notice supplements the other notices and
is not intended to override them.
Controller
Lochcarron
Leisure Centre Ltd is the controller and responsible for your personal data
(collectively referred to as the ”Company”, “we”, “us” or “our” in this privacy
notice).
If you have any questions about
this privacy notice, including any requests to exercise your legal rights,
please contact us using the details set out below.
Contact Details
Our full
details are:
Full name
of legal entity: Lochcarron
Leisure Centre Ltd
Name of
Contact: Dee
GIlks
Email
address: lochcarrongym @gmail.com
Postal
address: Lochcarron
Fitness Centre, Park Road, Lochcarron IV54 8YF
Telephone
number: 01520 722872 (unmanned but please leave a message and we will contact you)
You have the right to make a
complaint at any time to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal
with your concerns before you approach the ICO so please contact us in the
first instance.
Changes to the Privacy Notice and your duty to inform us of changes
This
version of Lochcarron Leisure Centre’s Privacy Notice is the first version.
It is important that the
personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your relationship with us.
Third-Party Links
Our website may include links to
third-party websites, plug-ins and applications. Clicking on those links or
enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible
for their privacy statements. When you leave our website, we encourage you to
read the privacy notice of every website you visit.
2. The data we collect about you
Personal
data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the
identity has been removed (anonymous data).
We may
collect, use, store and transfer different kinds of personal data about you
which we have grouped together follows:
·
Identity
Data includes first name,
maiden name, last name, username or similar identifier, marital status, title,
family and lifestyle information, date of birth and gender.
·
Contact
Data includes address, billing
address, emergency contact details, email address and telephone numbers.
·
Financial
Data includes bank account and
payment card details.
·
Transaction
Data includes details about
payments to and from you and other details of products and services you have
purchased from us.
·
Technical
Data includes internet protocol
(IP) address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform and
other technology on the devices you use to access this website.
·
Profile
Data includes your username and
password, purchases or orders made by you, your interests, preferences,
feedback and survey responses.
·
Usage
Data includes information about
how you use our website, products and services.
·
Marketing
and Communications Data includes
your preferences in receiving marketing from us and our third parties and your
communication preferences.
We also
collect, use and share Aggregated Data such
as statistical or demographic data for any purpose. Aggregated Data may be
derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For example, we
may aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data
with your personal data so that it can directly or indirectly identify you, we
treat the combined data as personal data which will be used in accordance with
this privacy notice.
We may collect Special
Categories of Personal Data about you (this may include details about your race
or ethnicity, religious or philosophical beliefs, sex life, sexual orientation,
information about your health and genetic and biometric data). We do not
collect any information about criminal convictions and offences.
If you fail to provide Personal Data
Where we need to collect
personal data by law, or under the terms of a contract we have with you and you
fail to provide that data when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide
you with goods or services). In this case, we may have to cancel a product or
service you have with us but we will notify you if this is the case at the
time.
3. How is your Personal Data collected?
We use
different methods to collect data from and about you including through:
Direct
interactions.
You may give us your Identity, Contact and Financial Data by filling in forms
or by corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
·
apply for
our products or services;
·
create an
account on our website;
·
subscribe
to our service or publications;
·
request
marketing to be sent to you;
·
enter a
competition, promotion or survey; or
·
give us
some feedback.
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 cookies policy.
Third parties
or publicly available sources. We may receive personal data about you from various third parties
and public sources as set out below:
Technical
Data from the following parties:
·
(a)
Analytics providers;
·
(b)
Advertising networks; and
·
(c) Search
for information providers.
Contact, Financial and
Transaction Data from providers of technical, payment and delivery services.
Identity and Contact Data from data brokers or aggregators.
Identity and Contact Data from publicly availably sources such as Companies
House and the Electoral Register based inside the EU.
4. 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.
·
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 sending third party 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 where
more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for
processing including the basis of legitimate interest |
|
To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
|
To process and deliver your order including: (a) Manage payments, fees
and charges (b) Collect and recover
money owed to us |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and
Communications |
(a) Performance of a contract with you (b) Necessary for our
legitimate interests (to recover debts due to us) |
|
To manage our relationship with you which will
include: (a) Notifying you about
changes to our terms, your account or our privacy policy (b) Asking you to leave a
review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and
Communications |
(a) Performance of a contract with you (b) Necessary to comply
with a legal obligation (c) Necessary for our
legitimate interests (to keep our records updated and to study how customers
use our products/services) |
|
To enable you to partake in a prize draw,
competition or complete a survey |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and
Communications |
(a) Performance of a contract with you (b) Necessary for our
legitimate interests (to study how customers use our products/services, to
develop them and grow our business) |
|
To administer and protect our business and our
website (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for
running our business, provision of administration and IT services, network
security, to prevent fraud and in the context of a business reorganisation or
group restructuring exercise) (b) Necessary to comply
with a legal obligation |
|
To deliver relevant website content and
advertisements to you and measure or understand the effectiveness of the
advertising we serve to you |
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study
how customers use our products/services, to develop them, to grow our
business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services,
marketing, customer relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define
types of customers for our products and services, to keep our website updated
and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you
about goods or services that may be of interest to you |
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to
develop our products/services and grow our business) |
Marketing
We strive to provide you with
choices regarding certain personal data uses, particularly around marketing and
advertising.
Promotional offers from us
We may use
your Identity, Contact, Technical, Usage and 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
goods or services from us or if you provided us with your details when you
entered a competition or registered for a promotion 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 company outside of Leisure
Centre Ltd for marketing purposes.
Opting Out
You can ask
us or third parties to stop sending you marketing messages at any time by
contacting us at any time.
Where you opt out of receiving
these marketing messages, this will not apply to personal data provided to us
as a result of a product/service purchase, product/service experience or other
transactions.
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 our
website may become inaccessible or not function properly. For more information
about the cookies we use, please see our cookies 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.
5. Disclosures of your Personal Data
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.
·
External
Third Parties as set out in the Glossary.
·
Specific
third parties such as GoCardless (who collect payments on our behalf), Stripe (online
payment processing platform), Mailchimp (marketing platform).
·
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.
6. International Transfers
Some of our
external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will
involve a transfer of data outside the EEA.
Whenever we
transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
·
Where we
use certain service providers, we may use specific contracts approved by the
European Commission which give personal data the same protection it has in
Europe. For further details, see European
Commission: Model contracts for the transfer of personal data to third
countries.
·
Where we
use providers based in the US, we may transfer data to them if they are part of
the Privacy Shield which requires them to provide similar protection to
personal data shared between the Europe and the US. For further details,
see European
Commission: EU-US Privacy Shield.
Please contact us if you want further information on the
specific mechanism used by us when transferring your personal data out of the
EEA.
7. Data Security
We have put
in place appropriate security measures to prevent your personal data from being
accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those employees,
agents, contractors and other third parties who have a business need to know.
They will only process your personal data on our instructions and they are
subject to a duty of confidentiality.
We have put in place procedures
to deal with any suspected personal data breach and will notify you and any
applicable regulator of a breach where we are legally required to do so.
8. Data Retention
How long
will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the
purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements.
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 requirements.
By law we
have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for six 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.
Your Legal Rights
Under
certain circumstances, you have rights under data protection laws in relation
to your personal data. Please click on the links below to find out more about
these rights:
·
Request access to your personal data.
·
Request correction of your personal data.
·
Request erasure of your personal data.
·
Object to processing of your personal data.
·
Request restriction of processing your
personal data.
·
Request transfer of your personal data.
·
Right to withdraw consent.
If you wish to exercise any of
the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee
to access your personal data (or to exercise any of the other rights). However,
we may charge a reasonable fee if your request is clearly unfounded, repetitive
or excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
What we may need from you
We may need to request specific
information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person who
has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all
legitimate requests within one month. Occasionally it may take us longer than a
month if your request is particularly complex or you have made a number of
requests. In this case, we will notify you and keep you updated.
Glossary
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/product 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
External
Third Parties
·
Service
providers acting as processors who provide IT and system administration
services and information security.
·
Professional
advisers acting as processors or joint controllers including lawyers, bankers,
auditors and insurers who provide consultancy, banking, legal, insurance and
accounting services.
·
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.
· GoCardless (who collect payments on our behalf),
Stripe (online payment processing platform), Mailchimp (marketing platform)
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