- the personal information we collect about you
- what we do with your information, and
- who your information might be shared with.
Who we are
We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The personal data we collect and use
We collect the following personal information about you:
- your name, email address and phone number when you contact us through the website or in person of over the phone
- your date of birth, postal address and payment details when you purchase products or services from us
- any other personal information you provide to us.
If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:
- give consent on his/her behalf to the processing of his/her personal data;
- receive on his/her behalf any data protection notices;
- give consent to the transfer of his/her personal data abroad; and
- give consent to the processing of his/her health information.
Special category information
We may ask you to provide sensitive personal information if we require it to provide a service to you. This information is now called special category information. If we request such information, we will explain why we are requesting it and how we intend to use it.
Special category information includes information relating to your racial or ethnic origin, your political opinions, your religious or philosophical beliefs, trade union membership or information concerning your health or your sex life.
We will only collect this above information with your explicit consent.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations;
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party; or
- you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Updating and enhancing customer records||For the performance of our contract with you or to take steps at your request before entering into a contract|
To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
|Statutory returns||To comply with our legal and regulatory obligations|
|To send our newsletter to you||You have given us consent. If you have consented to such receive marketing from us, you can opt out at anytime.|
In respect of our website, we collect information about you so that we can:
- identify you and manage any accounts you hold with us;
- process your order;
- conduct research, statistical analysis and behavioural analysis;
- carry out customer profiling and analyse your purchasing preferences;
- detect and prevent fraud;
- customise our website and its content to your particular preferences;
- notify you of any changes to our website or to our services that may affect you;
- carry out security vetting; and
- improve our services.
Who your information might be shared with
We may disclose your personal data to:
- other companies within our group;
- our agents and service providers;
- law enforcement agencies in connection with any investigation to help prevent unlawful activity or to comply with our legal and regulatory obligations;
- our insurers and brokers; and
- our bank.
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, eg in relation to the audit of our accounts. We will not share your personal information with any other third party.
How long we keep your personal information
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information for as long as is necessary:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your personal information for longer than necessary for the purposes set out in this policy. After one year from the termination of the contract, we will delete or anonymise your details.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal data from being accidentally lost, or used or accessed in an unauthorised way. Those processing your personal data will do so only in an authorised manner and are subject o a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal data and to certain other supplementary information that thisPolicy is already designed to address
- require us to correct any mistakes in your personal data which we hold
- require the erasure of personal data concerning you in certain situations
- receive personal data concerning you which you have provided to us and have the
- object at any time to processing of personal data concerning you for direct marketing right to transmit such data to a third party in certain situations.
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
- object in certain other situations to our continued processing of your personal data
- otherwise restrict our processing of your personal data in certain circumstances
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the GDPR.
If you would like to exercise any of the above rights, please contact us.
How to complain
We hope that we can resolve any query or concern you raise about our use of your personal data.
The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection aws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.
How to contact us
If you wish to contact us, please send an email to firstname.lastname@example.org or write to us at Shenley Leisure Centre, Burchard Crescent, Shenley Church End, Milton Keynes, MK5 6HF.