Clubz Limited (registered company number 10338601) is committed to protecting your privacy and personal data. At all times we aim to respect any personal information you share with us, or that we receive from others, and keep it safe. This Privacy Notice (“Notice”) sets out our data processing practices and your rights and options regarding the ways in which your personal information is used and collected, including through our websites, clubz.co.uk, myclubz.co.uk (regardless of where you visit it from), and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can easily access the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. Important information and who we are
Purpose of this privacy notice
The purpose of this privacy notice is to provide information on how Clubz Limited collects and processes your personal data through your use of this website. This includes any data you may provide through this website when you register to use our site, subscribe to our service or sign up for a free trial (whether as a club owner, administrator, manager or as a nominated user), participate in activities or other social media functions on our site, attend webinars, enter a competition, promotion or survey, and if you need to report a problem with our site.
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 may collect or process 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.
Clubz Limited is the controller and is responsible for your personal data (referred to as “Clubz”, “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.
Our full details are:
Full name of legal entity: Clubz Limited
Email address: email@example.com
Postal address: Pera Business Park, Nottingham Road, Melton Mowbray, Leicestershire, LE13 0PB.
Telephone number: 01664 784184.
You have rights 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). Please email us at firstname.lastname@example.org in the first instance to give us the chance to deal with your concerns before you approach the ICO.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on the 6th November 2018.
It is important that the personal data we hold about you is current and accurate. Please keep us informed if your personal data changes during your relationship with us.
Third party links
This website may include links to third party websites, plug-ins and applications. Selecting 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.
2. 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, store, use and transfer different kinds of personal data about you which we have grouped together and described as follows:
- Identity Data includes full name or similar identifier, personal description and photograph, and the name of your club or organisation. If you subscribe to our service (whether as a club owner, administrator, manager or as a nominated user) or sign up for a free trial, this will also include details about club members (such as their name, address and contact details) and their emergency contact details.
- Contact Data includes postal address, email address and telephone numbers.
- Transaction Data includes details about payments to and from you and other details of any services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data includes your email address and password, subscriptions made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- provided we have your explicit consent to use it, or in the case of nominated users, your team leader or organiser has obtained your explicit consent to their and our using it;
- where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent;
- where you have previously made that data public knowledge;
- if we need to use that data to establish, exercise or defend legal claims; or
- here there is some other legal basis that allows us to use that information.
- 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.
If you fail to provide personal data
In instances 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 services). In this case, we may have to cancel a service you have asked us to provide, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Special Category data by filling in forms on our site, through use of the Clubz app, or by corresponding with us by post, phone, email or otherwise.
- Indirect interactions. Your club administrator or manager may give us your Identity, Contact and Special Category data by filling in forms on our site, through use of the Clubz app, or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:
- register to use our site;
- subscribe to our service (whether as a club owner, administrator, manager or as a nominated user) or sign up for a free trial;
- participate in activities or other social media functions on our site, or attend webinars on our site;
- enter a competition, promotion or survey;
- request marketing to be sent to you; or
- report a problem with our site or give us some feedback.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies section for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- analytics providers such as Google based outside the EU;
- hosting and back up services providers such as Amazon Web Services using data centres within the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe Inc in relation to payment services.
- Identity, Contact and Special Category Data from your club owner, administrator, manager or nominated user.
- Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
4. 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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
We will only use Special Category Data:
- where we have your explicit consent to use it (either directly from you, or via your club owner, administrator, manager if you are a nominated user).
- where we believe that we need to use that data to protect your vital interests where you are not able to provide us with your explicit consent.
- where it is necessary for reasons of substantial public interest.
- where you have previously made that data public knowledge.
- if we need to use that data to establish, exercise or defend legal claims.
- where there is some other legal basis that allows us to use that information.
See the table below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to Special Category Data, or 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
The table below displays 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 email is at email@example.com 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 subscriber or nominated user, or to enable you to participate in a free trial||a) Identity|
|Performance of a contract with you|
|To provide our services to you, including:|
a) Manage payments, fees and charges
b) Collect and recover money owed to us
c) Special Category Data
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:|
b) Asking you to leave a review or take a survey
d) Marketing and Communications
|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 services)
|To enable you to partake in a prize draw, competition or complete a survey, or participate in a webinar||a) Identity|
e) Marketing and Communications
|a) Performance of a contract with you|
b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||a) Identity|
|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|
e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, services, marketing, customer relationships and experiences||a) Technical|
|Necessary for our legitimate interests (to define types of customers for our 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|
|Necessary for our legitimate interests (to develop our services and grow our business)|
We provide you with options regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control functions:
Promotional offers from us
We may use your Identity, Contact, Profile, Usage and Technical 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 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 (for example if you have subscribed to receive any of our publications, or have purchased services from us), and you have not opted out of receiving marketing information.
If you fail to provide personal data
You will receive marketing communications from us if you have requested information from us (for example if you have subscribed to receive any of our publications, or have purchased services from us), and you have not opted out of receiving that marketing information.
Third party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or 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 your entering into a service subscription or free trial, or any other transactions you have entered into with us.
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 email firstname.lastname@example.org
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.
5. Disclosures of your personal data
We may have to share your personal data with the parties identified below for the purposes set out in the first column in the table in paragraph 4 above.
- External Third Parties as described in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require 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.
6. 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 (as appropriate):
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For example, we use Stripe Inc. in relation to payment processing, and they are part of the Privacy Shield. For further details, see European Commission: EU-US Privacy Shield
Please email email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as deemed 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, sensitivity, and nature 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. This is all determined in accordance with the applicable legal requirements for data retention.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the sections below to find out more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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.
External Third Parties
- Service providers acting as processors, such as: Stripe Inc in connection with secure payment services; analytics providers such as Google based outside the EU; hosting and back up services providers such as Amazon WebServices using data centres within the EU.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, the Information Commissioner’s Office, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.