This Privacy Notice is issued, whether you are a member or supplier, or other individual about whom we control data, to provide you with information about what data we hold and process and what we do with that data.
This Privacy Notice explains clearly how we collect, process, store and share your data in line with our legal obligations under the UK GDPR and EU GDPR (referred to in this notice collectively a GDPR). If you have any questions about this notice, or the way in which we process your data, please do not hesitate to contact us using the details in the ‘How To Contact Us’ section.
Your Right To Be Informed - Our obligations to you in respect of the fair and transparent processing of your data.
Who We Are - Our details as the Data Controller.
How To Contact Us - Our full contact details.
Data We Hold - Explains what types of personal data we collect from you.
Special Category Data (SCD) - SCD is treated differently to personal data under GDPR, this section explains what SCD is and how we process it.
What We Do With Your Data - We may process your data in different ways, this section explains how we will use the data you provide.
Lawful Basis For Processing - Under the GDPR, we are required to have a lawful basis for processing your data. We may have more than one lawful basis so this section explains which bases may be used.
Marketing - This section contains information about how we will market to you and our lawful basis for doing so.
Sharing Your Information - It may be necessary for us to share your personal information, for us to provide our services to you. This section explains if we share your data, and who with.
Transfer of Personal Data Outside the UK - It may be necessary to transfer your personal data outside the UK. This section explains what happens when this is the case.
How Long We Retain Data - The retention period for the data we hold will depend on the type of data and how it has been processed. In all cases, we will not retain data for longer than is necessary. This section outlines our retention periods.
Your Data Protection Rights - The GDPR enshrines the rights of the data subject into law. This section outlines what rights you have as a data subject.
How To Make A Complaint - If you are unhappy with the way in which we process your data, please refer to this section as it outlines how you can make a complaint.
Your Right To Be Informed
The UK GDPR requires that we inform you about how we use the data we collect from/about you. We aim to process your data in a way which is lawful, fair and transparent.
Under Article 14 of UK GDPR, we must advise you where we have obtained your data from a third party. Before obtaining your data, we will take all reasonable steps to ensure that the party providing your data to us, has a lawful basis for doing so. Details of the third party who provide us with your data are available on request. Should you have any queries in respect of their data protection practices, you should contact them directly.
Who We Are
The Club Company (Group) Limited is registered in England No 09380365 (referred to hereafter as We or Us). For the purposes of the General Data Protection Regulations (GDPR) and the Data Protection Act 2018, we are data controllers. We are registered with the Information Commissioner’s Office Number ZA500945.
The Club Company, Bath Road, Knowl Hill, Reading, RG10 9AL
Email - email@example.com
Telephone - 01628 820750
Website - www.theclubcompany.com
Data We Hold
We collect personal data. Personal data is any information that may identify a living individual.
We collect the following personal data:
Medical data (collected for Gym membership)
Images captured by CCTV
We will collect in the process of making orders and engaging our services, in order that we may operate our business.
This data includes:
Images captured by CCTV
Special Category Data
Special category data includes information about criminal convictions, race or ethnic origin, political or religious beliefs, health, genetic or biometric data, sex life and sexual orientation, trade union membership and philosophical beliefs of an individual.
When processing special category data, we will do so with the utmost care and process the data in strict accordance with the legal requirements.
Where necessary, the express consent of the data subject will be obtained permitting us to process such data.
What we do with your data
All the data we hold will be processed for the purposes of providing services and facilities to our members.
Where the data collected concerns a child (under the age of 13), we will take appropriate and proportionate steps to inform the child’s parent or legal guardian.
Where a member is over the age of 13, but under the age of 18, we will take additional steps help them understand how we will process their data.
Members’ data will be used to provide our services which may include using the Intelligent Golf platform to book tee times, using the Technogym system as a gym member, making reservations in our hotels and restaurants and ordering food.
We will also use your data to keep you informed about the services, offers and events being offered by the venue at which you are a member.
Data is held across venues within The Club Company (Group) Limited. Data collected at each venue, for the purposes of marketing will be shared with our Head Office. Please refer to the Marketing section below.
In addition, this data may be used for our own general business purposes to facilitate:
Billing and debt collection
Advertising and marketing (where necessary your consent to receive marketing will be obtained)
Management information necessary to assess how we are performing as a business and client satisfaction with our services
Health and safety requirements to ensure the safety and security of our people and premises
Disclosure of information to our own professional and legal advisors
Complying with our legal obligations
Where we collect data for independent contractors, for example Swim Schools and Golf Pros, the data is captured in a manual format as provided by the contractor. We do not use this data for any other purpose. You should contact the independent contractors for more information about how they will process your data.
Lawful basis for processing
It is a requirement of the General Data Protection Regulations that data is processed only when there is a lawful basis for doing so.
The Club Company (Group) Limited’s legal basis for processing data will include one or more of the following:
The processing of data is necessary for the performance of a contract for membership to which you are a party or when taking steps in order to enter into a contract at your request
Processing is necessary for our compliance with our legal obligations
Processing is necessary for the purposes of pursuing our legitimate interest (including to keep you informed about the services, offers and events being offered by the venue at which you are a member and pursuing our general business interest)
The processing is necessary for the establishment, exercise or defence of legal claims
Where the processing is necessary in order to protect the vital interests of the data subject or of another natural person (for example in the case of a medical emergency)
Additionally, in some circumstances we may process personal data on the basis that an individual has provided their express consent, for example, for marketing to an individual by email or SMS or for the processing of special category data.
Please note that consent provided by an individual may be withdrawn by that individual at any time by contacting us using the contact details above.
We may wish to send marketing materials to you on the basis of our legitimate interests or, where necessary, having obtained the consent of the individual concerned, provided it is permissible for us to do so by law. It is the right of individuals to opt-out of or unsubscribe from any marketing material. Full details of how this can be done will be included within each marketing communication. You may also opt-out by contacting us at the above address.
Sharing your information
In order to provide our services to you we will share your data with third parties we engage as Data Processors.
These will be cloud based platforms which offer facilities to our members and will include:
Mr Yum (food ordering app)
Your Golf Booking
Your data may also be shared to facilitate club events such as competitions.
When booking a tee time online via the Intelligent Golf platform, the name of the member will appear on the electronic tee time sheet and will be visible to other members only. Members of the public or visitors to the club will not have access to this data. Should you not wish your name to be visible on the electronic tee booking sheet, you are invited to make a booking in person at the club, or to telephone the club. They will make the tee booking without including your name on the electronic sheet.
It may be necessary for us to share the personal data we hold, insofar as we are obliged or allowed by law to do so, with third parties including the following:
financial organisations, debt collection, credit reference and tracing agencies
suppliers and service providers used by us in order to deliver our services to you. This may include, including document storage facilities, IT service providers such as cloud providers of software, data room providers and providers of our IT servers
our own legal and other professional advisors
government agencies, regulators, the police/law enforcement agencies and other authorities (including the Information Commissioner and HMRC)
It may also be necessary to share personal data to comply with our legal obligations or for the establishment, exercise or defence of legal claims.
With your consent, we may also share your personal data with anyone you have authorised to deal with us on your behalf.
Transfer of personal data outside the UK
Where possible, we seek to ensure data we collect is stored securely within the UK. However, some data we collect may be transferred to, and stored at, a country outside of the UK and European Economic Area (EEA). This means it might also be processed by staff operating outside of the EEA who work for one of our suppliers.
Where information is provided to a Third Party, either in or outside the EEA, we will ensure that it and any of its agents and/or suppliers take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice.
How Long We Retain Data
In line with the requirements of GDPR we will retain any personal data we hold for no longer than is necessary for the purpose for which it was provided unless we are required by law, unless we have another legitimate reason to keep it for longer (for example if necessary for any legal proceedings).
Members' information (Name & Contact Details) - 5 years after membership lapses
Accounts data (membership) - 6 years from the end of the financial year in which payment was collected
CCTV images - 28 days
Supplier data - 2 years from date of last purchase/use of services
Marketing - 5 years. Individual marketing campaign data is retained for 30 days as automatically overwritten by new campaigns.
Your data protection rights
The data protection regulations and UK law seeks to protect your rights as follows:
The right to be informed. Individuals have the right to be told what personal data is collected about them, why, who is collecting the data, how long it will be held, how they can file a complaint and with whom your data will be shared.
The right of access. Individuals have the right to access the personal information and organisation holds about them. To request a copy of this information you must make a subject access request by contacting us using the contact details above.
The right of rectification. Individuals may ask an organisation to correct any inaccurate or incomplete data within one month.
The right to erasure. Individuals have the right to have your personal data erased and to prevent processing except where we have a legal obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide products and services.
Right to restrict processing. Individuals can request that an organisation limits the way it uses their personal data. This means that an organisation is not obligated to delete the data, but they have to refrain from processing it.
The right to data portability. On your request, we will provide you with your personal data in a structured format.
The right to object. Allows individuals to object to the processing of personal data at any time, in certain situations and will depend on the purpose of processing and the lawful basis for processing.
Rights in relation to automated decision making and profiling. You have particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes.
You may invoke any of these rights at any time by contacting us on the details given at the beginning of this Privacy Notice.
How to make a complaint
In addition to the rights listed above, any person about whom we hold personal data, also known as data subjects, have the right to make a complaint about how we have processed their data, or a data breach. In the first instance, we invite you to contact us at:
The Club Company, Bath Road, Knowl Hill, Reading, RG10 9AL
E – firstname.lastname@example.org
T – 01628 820750
Alternatively, data subjects can raise a complaint directly with the Information Commissioner. Information of how you can complain can be found at www.ico.org.uk/for-the-public/
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This Privacy Notice was last updated in July 2022.