CLUB10M+ PRIVACY NOTICE
a) This Privacy Notice explains how and why we use your personal data, to make sure you stay informed and can be confident about giving us your information.
b) We treat the handling of personal data seriously and we respect your privacy and your rights to control your personal data.
c) The Privacy Notice below details how we will treat your personal data after it has been collected by us through your use of the website, or through providing us with your details when you make an enquiry with us.
d) We assure you that we will only use your data as specified here and for our legitimate business interests.
e) In this Privacy Notice, “we”, “us” and “our” refer to Club10m+.
1. HOW WE COLLECT INFORMATION ABOUT YOU AND WHAT PERSONAL DATA DO WE COLLECT?
a) When you fill in forms on our website, register to use our website, complete a booking, sign up to our newsletter, consult with our team, send us an email, participate on social media, enter a competition, promotion or survey, or send us your CV, or communicate with us in any way you are voluntarily giving us your personal data.
b) This personal data you give us may include name, title, address, date of birth, age, gender, employment status, demographic information, email address, telephone numbers, personal description, photographs, CCTV images or credit/debit card details to take payment for contracted services.
c) In the interest of your privacy, we only collect, use and retain information required for our legitimate business interests, such as processing bookings and queries or providing you with our Group marketing materials
2. WHAT LAWFUL BASIS DO WE RELY ON TO COLLECT PERSONAL DATA?
a) Where you have actively engaged our services, our holding of your data is in order to process your booking, fulfil your travel arrangements and otherwise perform the contract we have with you. Therefore, the lawful basis for holding and processing your data would be a “contractual” basis.
b) You may be providing personal data to us in order for us to provide services to a third party. For example, we may be engaged by a third party to provide certain travel, booking, or administrative services and such services require the processing of your personal data in order to provide these services. In these circumstances where there is no direct contractual relationship between us we are collecting and processing your personal data on the basis of legitimate interest. By providing us with your data for this purpose you accept and agree that the basis upon which we are processing your personal data is legitimate interest. We will only process your data in accordance with the GDPR.
c) We would also retain and process your personal data if there is a legal obligation to do so. In order to operate (provide our services to you) and improve our business (enhance your experience), there is also a valid legitimate interest basis for holding and processing your data.
d) We might also have requested your explicit consent in order to use your personal data. Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another lawful basis). To withdraw consent to our processing of your personal data please email us at email@example.com.
3. PRINCIPLES FOR COLLECTION AND PROCESSING OF PERSONAL DATA
a) Club10m+ has adopted the following principles to support and govern its collection and processing of Personal Data:
- Personal Data shall be processed lawfully, fairly, and in a transparent manner.
- Personal Data shall only be retained for as long as it is required to fulfil contractual requirements, or to provide statistics to our Group.
- Personal Data shall be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and/or processed.
- Personal Data shall be accurate and, where necessary, kept up to date.
- The Data Subject has the right to request from Club10m+ access to and rectification or erasure of their personal data, to object to or request restriction of processing concerning the data, or to the right to data portability.
4. DISCLOSURE OF YOUR DATA
a) We may disclose your personal information to any member of our Group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
b) We may disclose your personal information to third parties if we sell or buy any business or assets (in which case we may disclose your personal data to the prospective seller or buyer of such business or assets).
c) We may disclose your data to certain permitted third parties, such as third-party service providers or cloud service providers, to comply with contractual obligations.
e) We will never sell your personal data and will only share it with organisations we work with when it’s necessary and the privacy and security of your data is assured.
5. TRANSFER OF DATA TO THIRD PARTIES
a) We will not share your information with anyone outside our Group except: a) where we have your permission; b) where required to provide you, your agents or your contracting parties with our services; c) where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies around the world; d) with third parties who are providing services to us; e) with debt collection agencies; f) with credit reference and fraud prevention agencies; g) where required for a proposed sale, reorganisation, transfer, financial arrangement, asset disposal or other transaction relating to our business and/or assets held by our business; or h) where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.
b) We do not transfer personal data outside of the European Economic Area.
6. PERSONAL DATA RETENTION POLICY
a) We will keep your information for as long as we need it for the purpose it is being processed for, considering any legal obligation we have (e.g. to maintain records for fiscal or reporting purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). We will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to our services. The information may also be retained so that we can continue to improve your experience with us.
b) We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information in a timely manner.
7. INDIVIDUALS’ RIGHTS AND HOW TO EXERCISE THEM
a) Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. We are the data controllers, where we decide how and why personal data is processed.
8. DATA SUBJECT RIGHT
I. A right to know what data is processed, how it is processed and shared and to receive a copy of their personal data
II. A right to erasure, where there are no laws or regulations which mandate the retention of that data
III. A right to rectification of inaccurate personal data
IV. A right to withdraw their consent
V. A right to data portability
VI. A right to restriction of processing of specific personal data items
VII. A right to object to processing performed in the legitimate interests of Club10m+ subject with the objection evaluated in the context of the risk to the data subject
VIII. A right to object to direct marketing and have the direct marketing ceased immediately
IX. A right not to be subject to a decision based solely on automated processing
X. A right to claim compensation for damages caused by a breach of the Act
9. ACCESS TO PERSONAL DATA
a) You have a right of access to personal data held by us as a data controller. You also have the right to ask Club10m+ not to process your personal data for marketing purposes.
b) Your right to access can be exercised in accordance with the EU General Data Protection Regulation 2016 by completing a Data Subject Access Request (DSAR) Form. You can obtain a copy by emailing firstname.lastname@example.org.
c) To progress your request two forms of identification (ID) will also be required before any data is compiled, please have one form of photo ID (either a valid passport or driving license) AND a valid proof of address, Utility Bill/Council Tax Bill / Bank Statement/Credit Card Statement (One document required). These must be dated within the last three months.
d) Once we are satisfied that you meet the criteria for disclosure of data under the Data Protection Legislation and you have provided sufficient information for us to confirm your identity and accept your application for processing, you will receive a response within 28 days from that date.
e) Please note your request may be subject to an extension of up to two calendar months should the situation require it. A charge may be made, for this, if the retrieval of records is unreasonably time consuming
10. AMENDMENT OF PERSONAL DATA
a) To update personal data submitted to us, you may email us at email@example.com.
b) When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
11. ‘UNSUBSCRIBE’ TO MARKETING
a) Recipients of marketing material from any of our Group companies are likely to have previously subscribed to our newsletters, responded to an event invitation or used our services.
b) If you are a regular recipient and wish to continue receiving our newsletters (including special offers) you do not need to do anything at this point. If you no longer wish to receive these please unsubscribe by sending an email to firstname.lastname@example.org. Your details will be deleted from our records provided there is no other reason to retain them, as described in this privacy Notice.
c) You can unsubscribe at any point by clicking on the relevant link in any of our future newsletters. You can re‐subscribe again on our website at any time.
a) We take the security of all the data we hold very seriously. We follow internationally recognised security standards. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
a) Club10m+ may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalised service.
They enable us:
1) To estimate our audience size and usage pattern.
2) To store information about your preferences and so allow us to customise our site according to your individual interests.
3) To speed up the user experience.
4) To recognise you when you return to our site.
b) Please note that no attempts are made to identify individual users or store personal information. Cookies cannot harm your computer.
d) Please note cookies can be removed from your device at any time by wiping your Internet Browsers cache. Details of how to do this can be found online using the search term ‘Delete Cookies’
e) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
f) Bland Group operates in accordance with the EU General Data Protection Regulation 2016, and any amendments thereto.
g) Encryption and anonymization. Where possible personally identifiable information will be encrypted and/or anonymised, to ensure the security of the data itself and to minimise any potential exposure, should any breach occur.
i) For further information on cookies please contact us at email@example.com.
a) We understand the importance of protecting children’s information, especially in an online environment, and we do not knowingly collect or maintain information about children. If you learn that a child under the age of 13 has provided us with their personal information without having parental consent, please contact us immediately at firstname.lastname@example.org so that we can take appropriate action.
15. THIRD PARTY WEBSITES
a) Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
b) Our website includes links to other websites, whose privacy practices may be different from ours. If you submit personally identifiable information to any of those sites, your information is governed by their privacy policies.
c) We encourage you to carefully read the privacy Notice of any website you visit.
16. CHANGES TO THIS PRIVACY NOTICE
a) We recognise that transparency is an ongoing responsibility, so we will keep this privacy notice under regular review.
c) If such changes are overall disadvantageous to you, you may object to them within 20 days after their being posted on our Website or delivered to you, in which case none of the proposed changes will be effective with respect to information that we have already collected; but only to information we collect in the future.
d) You should check this page occasionally to ensure you are happy with any changes to this Notice.
e) This privacy statement was last updated on 25th May 2018.
a) If you are concerned about an alleged breach of privacy law or any other regulation by Club10m+, you can contact us via email email@example.com.
b) If you are not satisfied with the way in which Club10m+ has resolved your complaint, you have the right to complain to the data protection authority in your country. You may also refer the matter to a court of competent jurisdiction.
If you have any questions or concerns about the information we hold about you, you may email us at firstname.lastname@example.org.