Privacy
policy
1. Introduction
1.1 We
are committed to safeguarding the privacy of our website visitors, membership
base, individual customers and staff.
1.2 This
policy applies where we are acting as a data controller with respect to the
personal data of such persons; in other words, where we determine the purposes
and means of the processing of that personal data.
1.3 Our
website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can specify whether you would
like to receive direct marketing communications and limit the collection,
sharing and publication of your personal data. You can access the privacy
controls via your membership profile.
1.4 We
use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of [our website and services], we will ask you to consent to
our use of cookies when you first visit our website.
1.5 In
this policy, "we", "us" and "our" refer to RJT
Leisure Ltd.[ For more information about us, see Section 14.]
2. Credit
2.1 This
document was created using a template from Docular (https://seqlegal.com/free-legal-documents/privacy-policy).
3. The personal data that we collect
3.1 In
this Section 3 we have set out the general categories of personal data that we
process[ and, in the case of personal data that we did not obtain directly from
you, information about the source and specific categories of that data].
3.2 We
may process data enabling us to get in touch with you ("contact data").[
The contact data may include [your name, email address, telephone number,
postal address and/or social media account identifiers].][ The source of the
contact data is [you].][ If you log into our website using a social media
account, we will obtain elements of the contact data from the relevant social
media account provider.]
3.3 We
may process [your website user account data] ("account data").[
The account data may [include your account identifier, name, email address,
business name, account creation and modification dates, website settings and
marketing preferences].][ The primary source of the account data is [you and/or
your employer, although some elements of the account data may be generated by our
website].][ If you log into our website using a social media account, we will
obtain elements of the account data from the relevant social media account
provider.]
3.4 We
may process [information relating to transactions, including purchases of goods
and/or services, that you enter into with us and/or through our website]
("transaction data").[ The transaction data may include [your
name, your contact details, your payment card details (or other payment
details) and the transaction details].][ The source of the transaction data is
[you and/or our payment services provider].
3.5 We
may process [information contained in or relating to any communication that you
send to us or that we send to you] ("communication data"). The
communication data may include [the communication content and metadata
associated with the communication].[ Our website will generate the metadata
associated with communications made using the website contact forms.]
3.6 We
may process [data about your use of our website and services] ("usage
data"). The usage data may include [your IP address, geographical
location, browser type and version, operating system, referral source, length
of visit, page views and website navigation paths, as well as information about
the timing, frequency and pattern of your service use]. The source of the usage
data is [our analytics tracking system].
4. Purposes of processing and legal bases
4.1 In
this Section 4, we have set out the purposes for which we may process personal
data and the legal bases of the processing.
4.2 Operations
- We may process [your personal data] for [the purposes of operating our
website, the processing and fulfilment of orders, providing our services,
supplying our goods, generating invoices, bills and other payment-related
documentation, and credit control]. The legal basis for this processing is [our
legitimate interests, namely [the proper administration of our website,
services and business]] OR [the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a contract].
4.3 Publications
- We may process [account data] for [the purposes of publishing such data
on our website and elsewhere through our services in accordance with your
express instructions]. The legal basis for this processing is [consent] OR [our
legitimate interests, namely [the publication of content in the ordinary course
of our operations]] OR [the performance of a contract between you and us and/or
taking steps, at your request, to enter into such a contract].
4.4 Relationships
and communications - We may process [contact data, account data,
transaction data and/or communication data] for [the purposes of managing our
relationships, communicating with you (excluding communicating for the purposes
of direct marketing) by email, SMS, post, fax and/or telephone, providing
support services and complaint handling]. The legal basis for this processing
is [our legitimate interests, namely [communications with our website visitors,
service users, individual customers and customer personnel, the maintenance of
relationships, and the proper administration of our website, services and
business]].
4.5 Direct
marketing - We may process [contact data, account data and/or transaction
data] for [the purposes of creating, targeting and sending direct marketing
communications by email, SMS, post and/or fax and making contact by telephone
for marketing-related purposes]. The legal basis for this processing is
[consent] OR [our legitimate interests, namely [promoting our business and
communicating marketing messages and offers to our website visitors and service
users]].
4.6 Research
and analysis - We may process [usage data and/or transaction data] for [the
purposes of researching and analysing the use of our website and services, as
well as researching and analysing other interactions with our business]. The
legal basis for this processing is [consent] OR [our legitimate interests,
namely [monitoring, supporting, improving and securing our website, services
and business generally]].
4.7 Record
keeping - We may process [your personal data] for [the purposes of creating
and maintaining our databases, back-up copies of our databases and our business
records generally]. The legal basis for this processing is our legitimate
interests, namely [ensuring that we have access to all the information we need
to properly and efficiently run our business in accordance with this policy].
4.8 Security
- We may process [your personal data] for [the purposes of security and the
prevention of fraud and other criminal activity]. The legal basis of this
processing is our legitimate interests, namely [the protection of our website,
services and business, and the protection of others].
4.9 Insurance
and risk management - We may process [your personal data] where necessary
for [the purposes of obtaining or maintaining insurance coverage, managing
risks and/or obtaining professional advice]. The legal basis for this
processing is our legitimate interests, namely [the proper protection of our
business against risks].
4.10 Legal
claims - We may process [your personal data] where necessary for [the
establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure]. The legal basis
for this processing is our legitimate interests, namely [the protection and
assertion of our legal rights, your legal rights and the legal rights of
others].
4.11 Legal
compliance and vital interests - We may also process your personal data
where such processing is necessary for compliance with a legal obligation to
which we are subject or in order to protect your vital interests or the vital
interests of another natural person.
5. Providing your personal data to others
5.1 We
may disclose [your personal data] to [our insurers and/or professional
advisers] insofar as reasonably necessary for the purposes of [obtaining or
maintaining insurance coverage, managing risks, obtaining professional advice].
5.2 [Your
personal data held in our website database] OR [[Identify personal data
category or categories]] will be stored on the servers of our hosting
services providers https://www.delicious-webdesign.com/
5.4 Financial
transactions relating to [our website and services] [are] OR [may be] handled
by our payment services providers, Worldpay, Stripe & GoCardless. We
will share transaction data with our payment services providers only to the
extent necessary for the purposes of [processing your payments, refunding such
payments and dealing with complaints and queries relating to such payments and
refunds]. You can find information about the payment services providers'
privacy policies and practices at https://gocardless.com/
, https://www.fisglobal.com/en/merchant-solutions-worldpay
and https://stripe.com/gb/privacy
5.5 In
addition to the specific disclosures of personal data set out in this Section
5, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise, or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.
6. International transfers of your personal
data
6.1 You
acknowledge that [personal data that you submit for publication through our
website or services] may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.
7. Retaining and deleting personal data
7.1 This
Section 7 sets out our data retention policies and procedures, which are
designed to help ensure that we comply with our legal obligations in relation to
the retention and deletion of personal data.
7.2 Personal
data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.
7.3 We
will retain your personal data as follows:
(a) contact
data will be retained for a minimum period of 2 years following the date
of the most recent contact between you and us. and for a maximum period of 1
year following that date];
(b) account
data will be retained for a minimum period of 2 years following the date
of closure of the relevant account, and for a maximum period of 1 year
following that date];
(c) [transaction
data will be retained for a minimum period of 2 years following the date
of the transaction, and for a maximum period of 1 year following that date];
(d) [communication
data will be retained for a minimum period of 2 years following the date
of the communication in question, and for a maximum period of 1 year
following that date];
7.4 Notwithstanding
the other provisions of this Section 7, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.
8. Your rights
8.1 In
this Section 8, we have listed the rights that you have under data protection
law.
8.2 Your
principal rights under data protection law are:
(a) the
right to access - you can ask for copies of your personal data;
(b) the
right to rectification - you can ask us to rectify inaccurate personal data
and to complete incomplete personal data;
(c) the
right to erasure - you can ask us to erase your personal data;
(d) the
right to restrict processing - you can ask us to restrict the processing of
your personal data;
(e) the
right to object to processing - you can object to the processing of your
personal data;
(f) the
right to data portability - you can ask that we transfer your personal data
to another organisation or to you;
(g) the
right to complain to a supervisory authority - you can complain about our
processing of your personal data; and
(h) the
right to withdraw consent - to the extent that the legal basis of our
processing of your personal data is consent, you can withdraw that consent.
8.3 These
rights are subject to certain limitations and exceptions. You can learn more
about the rights of data subjects by visiting https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/.
8.4 You
may exercise any of your rights in relation to your personal data [by written
notice to us, using the contact details set out below].
9. About cookies
9.1 A
cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.
9.2 Cookies
may be either "persistent" cookies or "session" cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.
9.3 Cookies
may not contain any information that personally identifies a user, but personal
data that we store about you may be linked to the information stored in and
obtained from cookies.
10. Cookies that we use
10.1 We
use cookies for the following purposes:
(a) [authentication
and status - we use cookies [to identify you when you visit our website and
as you navigate our website, and to help us determine if you are logged into
our website.
(b) [shopping
cart - we use cookies to [maintain the state of your shopping cart as you
navigate our website.
(c) [personalisation
- we use cookies [to store information about your preferences and to
personalise our website for you.
(d) [security
- we use cookies [as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally.
(e) [advertising
- we use cookies [to help us to display advertisements that will be relevant to
you.
(f) [analysis
- we use cookies [to help us to analyse the use and performance of our website
and services.
(g) [cookie
consent - we use cookies [to store your preferences in relation to the use
of cookies more generally.
11. Cookies used by our service providers
11.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.
11.2 We
use Google Analytics. Google Analytics gathers information about the use of our
website by means of cookies. The information gathered is used to create reports
about the use of our website. You can find out more about Google's use of
information by visiting https://www.google.com/policies/privacy/partners/
and you can review Google's privacy policy at https://policies.google.com/privacy.[
The relevant cookies are: [identify cookies].]
12. Managing cookies
12.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:
(a) https://support.google.com/chrome/answer/95647
(Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) https://help.opera.com/en/latest/security-and-privacy/
(Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);
(e) https://support.apple.com/en-gb/guide/safari/manage-cookies-and-website-data-sfri11471/mac
(Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).
12.2 Blocking
all cookies will have a negative impact upon the usability of many websites.
12.3 If
you block cookies, you will not be able to use all the features on our website.
13. Amendments
13.1 We
may update this policy from time to time by publishing a new version on our
website.
13.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.
13.3 We
[may] OR [will] notify you of [changes] OR [significant changes] to this policy
[by email].
14. Our details
14.1 This
website is owned and operated by RJT Leisure Ltd
14.2 We
are registered in [England and Wales] under registration number 10905910 , and
our registered office is at 27 Beechcroft Road, Bushey WD23 2JU.
14.3 Our
principal place of business is at Unit 3, Lagoon Road, Orpington, Kent, BR5
3QX.
14.4 You
can contact us:
(a) [by
post, to [the postal address given above]];
(b) [using
our website contact form];
(c) [by
telephone, on [the contact number published on our website]]; or
(d) [by
email, using [the email address published on our website]].
15. Data protection officer
15.1 Our
data protection officer's contact details are: Managing Director, Unit 3
Lagoon Road, Orpington, Kent, BR5 3QX.