Writhlington Leisure understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website including our online services platform www.writhlingtonleisure.co.uk Our website will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of our Site;|
|“Cookie”||means a small text file placed on your computer or device by our site when you visit certain parts of our site and/or when you use certain features of our site. Details of the Cookies used by our Site are set out in Part 14, below; and|
|“Cookie Law”||means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;|
1. Information About Us
Our website is owned and operated by Writhlington Trust, a charitable limited by guarantee company registered in England and Wales under company number 4757263 and Charity Number 1111515
Registered address: Writhlington Trust, Writhlington Leisure, Knobsbury Lane, Writhlington, Radstock
VAT number: 909 432 912
Email address: email@example.com
Telephone number: 01761 252631
3. What Does This Policy Cover?
4. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
6. What Data Do We Collect?
- Date of birth;
- Email address;
- Telephone number;
- Payment information;
- Information about your preferences and interests;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on our site, and the site you exit to;
7. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will OR may be used for one of the following purposes:
- Providing and managing your Account;
- Providing and managing your access to our site;
- Personalising and tailoring your experience on our site;
- Supplying our products AND/OR services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products AND/OR services for you.
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email AND/OR post that you have opted-in to, you may unsubscribe or opt-out at any time.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email AND/OR telephone AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
8. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We have data retention policies in place to ensure that data is either deleted or anonymised. Some data is anonymised rather than deleted at the end of the retention period for the purposes of statistical analysis to improve the products and services offered. The following data is anonymised:name, address, email address, telephone numbers, health and medical notes, workout notes, messages. This ensures that no personally-identifiable information remains on our systems.
9. How and Where Do You Store or Transfer My Personal Data?
We store your data via google drive for business, this is protected as part of the EU-US Privacy Shield. This requires third parties to provide data protection to similar standards of those in Europe. More information is available from the European Commission.
The security of your personal data is important to us and to protect your data, we take a number of important measures, including the following:
- Ensure that any third party software partners are GDPR compliant
- Have data processing agreements with our third party software partners
- Where possible upload hard copy forms containing any personal information to a secure encrypted and restricted digital format (google drive for business). Hard copies are then shredded.
- Any hard copy forms that are not uploaded are kept securely on site and are restricted to nominated staff. These forms are shredded in line with relevant retention period.
- Robust and regularly updated next generation firewall
10. Do You Share My Personal Data?
We contract with the following third parties to supply products AND/OR services to you on our behalf. In some cases, those third parties may require access to some or all of your personal data that we hold.
- Delta Computer Services – UK based leisure management software provider who is GDPR compliant. Your personal data is collected and stored on a bookings and membership database that they supply. This software is located on a secure server on our premises. Delta Compuer Services may, from time to time, be required to gain remote access to the server, for the purposes of technical support.
- The Retention People (TRP) – UK based customer experience management software provider who is GDPR compliant. TRP are a data processor of our fitness member details. We use this software to
- Identify members using our fitness facilities
- Store information on our members including height, weight, body fat, BMI and medical history
- Data is used to decide which customers will receive NPS Survey emails to provide feedback for analysis
- Data is used to trigger interactions to help our fitness instructors to engage with members to support them achieve their fitness goals
- Data is used to support our fitness instructors engage and track progress of our fitness members on a range of fitness measures
- Pulse Fitness – UK based fitness equipment and member software provider who is GDPR compliant. We use their cloud-based product called Pulsemove. This is a membership database for the purposes of fitness programme prescription. We use the software to
- Write fitness programmes for our fitness members
- Track their attendance
- Track their progress
- CoursePro – UK based sports course software management provider who is GDPR compliant. CoursePro are a data processor of our sports course customer details. We use this software to
- Take registers / track attendance
- Assess the progress of attendees against National Governing Body or our own award schemes
- Produce management reports in relation to attendance, occupancy and assessments
- Other Sports Clubs – Personal information regarding attendees on our sports courses (gymnastics, tennis, trampoline, dance etc) may be shared with other sports clubs / organisations for the purposes of competition or exam entry. Where we do this your express consent will be required for each entry.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
11. How Can I Control My Personal Data?
- In addition to your rights under the GDPR, set out in Part 5, when you submit personal data via our website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your account.
12. Can I Withhold Information?
You may access certain areas of our site without providing any personal data at all. However, to use all features and functions available on our website you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
All Cookies used by and on our website are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, a pop-up requesting your consent to set those Cookies will be shown. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our website or online bookings platform may not function fully or as intended.
Certain features of our website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. You can block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our website may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our website more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
15. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Contact Name: Matt Wise, Director of Leisure
Email address: firstname.lastname@example.org
Telephone number: 01761 252631
Postal Address: Writhlington Leisure, Knobsbury Lane, Writhlington, Radstock, BA3 3NQ
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.