Privacy

INTRODUCTION  

Welcome to ClubRight Ltd’s privacy notice.

 

ClubRight Ltd 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 ClubRight 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  

 

ClubRight 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: ClubRight Ltd

 

Name of contact: Wayne Heath

 

Email address: Wayne@clubright.co.uk

 

Postal address: Unit 5 The Stables & The Courtyard, Lake Meadows Business Park, Woodbrook Crescent,
Billericay CM12 0EQ

 

Telephone number: 0203 884 9777

 

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 ClubRight Ltd’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.

 

  1. 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:

 

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.

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

 

We use different methods to collect data from and about you including through:

 

      (a)  analytics providers;

 

(b)  advertising networks; and

 

(c)  search information providers.

 

 

 

  1. 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:

 

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 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

(c) Providing you with our service/product

 

(a) Identity

(b) Contact

(c) Financial

(d) Profile

(e) Marketing and Communications

(f) Transaction

(g) Technical

(h) Usage

(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 ClubRight 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.

 

  1. 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.

 

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.

 

  1. 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:

 

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

  1. 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.

 

  1. 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.

 

  1. 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:

 

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.

 

  1. 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  

 

  1. GoCardless (platform allowing you to create your members Direct Debit payments);
  2. Mailchimp (marketing platform which allows you to push your members’ data into Mailchimp from our product/service to create marketing campaigns. You can opt out of or opt into this feature to ensure your members’ wishes are adhered to when using MailChimp);
  3. Harlands (platform allowing you to create your members Direct Debit payments);
  4. Debit Finance Collections Revenue Management Solutions (platform allowing you to create your members Direct Debit payments);
  5. eGym (each time a member of your gym joins using our integrated service they can open an eGym account to use the eGym Trainer App);
  6. The Code Guy – (a software development partner which assists us in the development and maintenance of our product/service).

YOUR LEGAL RIGHTS  

 

You have the right to:

 

 

 

 

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.