Privacy Policy Notice
For: The Climbing Academy Ltd & Undercover Rock Ltd

THE CLIMBING ACADEMY LTD & UNDERCOVER ROCK LTD (“TCA”, “UCR”, “we”, “us”) (registered company numbers 06388121 & 02599639) are committed to protecting your privacy. 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 – www.theclimbingacademy.com & www.undercover-rock.com).

This Notice contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.

Please note that this notice applies to both our customers and our staff and as such may make reference to types of information only relevant to one or other of those groups.

The provision of your personal information to us is voluntary. However, without providing us with your personal information, your use of our services or your interaction with us may be impaired. For example, you may be unable to sign up as a member, or make an online booking.

Contents of this policy:

Privacy Policy Notice

For: The Climbing Academy Ltd & Undercover Rock Ltd

Contents of this policy:

1.     We collect personal information about you:

a.     When you give it to us directly

b.     When we obtain it indirectly

c.     When it is available publicly

d.     When you visit our website

2.     What personal information do we use?

Do we process special categories of data?

3.     How and why will we use your personal information?

4.     Lawful bases

5.     Communications for marketing/promotional purposes

6.     Children’s personal information

7.     How long do we keep your personal information?

8.     Will we share your personal information?

9.     Security/storage of and access to your personal information

10.  International Data Transfers

11.  Exercising your Rights

12.  Changes to this Notice

13.  Links and third parties

14.  How to contact us

 

1.     We collect personal information about you:
a.     When you give it to us directly

For example, personal information that you submit through our website by making a booking to use our facilities, registering as a member or signing up for our email newsletter; or personal information that you give to us when you communicate with us by email, phone or letter.

b.     When we obtain it indirectly

For example, your personal information may be shared with us by third parties including, for example, the Association of Climbing Walls (Britain) Limited (“ABC”), an organisation established to promote safe management practices in climbing walls of which we are a member; third party service providers; analytics providers and search information providers. To the extent we have not done so already, we will notify you when we receive personal information about you from them and tell you how and why we intend to use that personal information.

c.     When it is available publicly

Your personal information may be available to us from external publicly available sources. For example, depending on your privacy settings for social media services, we may access information from those accounts or services (for example when you choose to interact with us via Facebook, Instagram, Twitter and Google).

d.     When you visit our website

When you visit our website, we automatically collect the following types of personal information:

(a)   Technical information, including the internet protocol (IP) address used to connect your device to the internet, browser type and version, time zone setting, browser plug-in types and versions and operating systems and platforms.

(b)   Information about your visit to the websites, including the uniform resource locator (URL) clickstream to, through and from the website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, referral sources, page interaction information (such as scrolling and clicks) and methods used to browse away from the page.

[We may collect and use your personal information by using cookies on our website – please see our Cookie Policy Notice].

In general, we may combine your personal information from these different sources set out in a-d above, for the purposes set out in this Notice.

2.     What personal information do we use?

We may collect, store and otherwise process the following kinds of personal information :

a.     your name and contact details including postal address, telephone number, email address, emergency contact details and, where applicable, social media identity;

b.     your date of birth and gender;

c.     your financial information, such as bank details and/or credit/debit card details, where this is done, it is kept in a secure and limited way, or it is held for us by a regulated financial services provider (for example Worldpay, Stripe);

d.     information about your computer/mobile device and your visits to and use of our websites, including, for example, your IP address and geographical location;

e.     personal descriptions and photographs;

f.      details of your qualifications/experience;

g.     information about your level of fitness & climbing performance

and/or any other personal information which we obtain as per paragraph 1.

Do we process special categories of data?

The EU General Data Protection Regulation (“GDPR”) recognises certain categories of personal information as sensitive and therefore requiring more protection, for example information about your health, ethnicity and religious beliefs.

In certain situations, TCA/UCR may collect and/or use these special categories of data (for example, information on climbers’ medical conditions relevant to their use of our facilities or on external expeditions organised by us). We will only process these special categories of data if there is a valid reason for doing so and where the GDPR allows us to do so.

 

3.     How and why will we use your personal information?

Your personal information, however provided to us, will be used for the purposes specified in this Notice. In particular, we may use your personal information:

a.     to register you as a member of TCA/UCR;

b.     to allow you to make a booking to use our facilities;

c.     to otherwise provide you with services, products or information you have requested;

d.     to provide further information about our work, services or activities (where necessary, only where you have provided your consent to receive such information);

e.     to assist you with certification schemes, such as NICAS/NIBAS;

f.      to answer your questions/requests and communicate with you in general;

g.     to allow you to apply for a job or volunteer role with us;

h.     to manage relationships with our partners and service providers;

i.       to analyse and improve our work, services, activities, products or information (including our website), or for our internal records;

j.       to keep our facilities safe and secure;

k.     to run/administer the activities of the Wall, including our website, and ensure that content is presented in the most effective manner for you and for your device;

l.       to audit and/or administer our accounts;

m.    to satisfy legal obligations which are binding on us, for example in relation to regulatory, government and/or law enforcement bodies with whom we may work (for example requirements relating to the payment of tax or anti-money laundering);

n.     for the prevention of fraud or misuse of services; and/or

o.     for the establishment, defence and/or enforcement of legal claims.

p.    To use your emergency contact details in the advent of an emergency or accident.

 

4.     Lawful bases

The GDPR requires us to rely on one or more lawful bases to use your personal information. We consider the grounds listed below to be relevant:

Where you have provided your consent for us to use your personal information in a certain way (for example, we may ask for your consent to use your personal information to send you email newsletters, or to collect special categories of your personal information. Special categories of personal information are explained in paragraph 2 above).

Where necessary so that we can comply with a legal obligation to which we are subject (for example, where we are obliged to share your personal information with regulatory bodies which govern our work and services).

Where necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering a contract (for example, to provide you access to our facilities in return for your booking fee, admission fee or subscription).

Where it is in your/someone else’s vital interests (for example, in case of medical emergency suffered by a climber).

Where there is a legitimate interest in us doing so.

The GDPR allows us to collect and process your personal information if it is reasonably necessary to achieve our or others’ legitimate interests (as long as that processing is fair, balanced and does not unduly impact your rights as an individual).

In broad terms, our “legitimate interests” means the interests of running TCA and UCR as commercial entities and ensuring the best possible user experience.

When we process your personal information to achieve such legitimate interests, we consider and balance any potential impact on you (both positive and negative), and on your rights under data protection laws. We will not use your personal information for activities where our interests are overridden by the impact on you, for example where use would be excessively intrusive (unless, for instance, we are otherwise required or permitted to by law).

5.     Communications for marketing/promotional purposes

We may use your contact details to provide you with information about our work, events, services and/or activities which we consider may be of interest to you (for example, about services you previously used, or events involving our, or other walls’, facilities).

Where we do this via email, SMS or telephone (where you are registered with the Telephone Preference Service), we will not do so without your prior consent (unless allowed to do so via applicable law).

Where you have provided us with your consent previously but do not wish to be contacted by us about our work, events, services and/or activities in the future, please let us know by using our online form found at theclimbingacademy.com/mytca or by emailing dpo@theclimbingacademy.com. You can opt out of receiving emails from TCA/UCR at any time by clicking the “unsubscribe” link at the bottom of our emails .

6.     Children’s personal information

When we process children’s personal information, we will not do so without their consent or, where required, the consent of a parent/guardian. We will always have in place appropriate safeguards to ensure that children’s personal information is handled with due care and in conjunction with our Safeguarding Children & Vulnerable Groups Policy.

7.     How long do we keep your personal information?

In general, unless still required in connection with the purpose(s) for which it was collected and/or processed, we remove your personal information from our records six years after the date it was collected. However, if before that date (i) your personal information is no longer required in connection with such purpose(s), (ii) we are no longer lawfully entitled to process it or (iii) you validly exercise your right of erasure (please see Section 11 below), we will remove it from our records at the relevant time. For further details on this please ask to see our Data Retention Policy.

If you request to receive no further contact from us, we may keep some basic information about you on our suppression list in order to comply with your request and avoid sending you unwanted materials in the future.

8.     Will we share your personal information?

We do not share, sell or rent your personal information to third parties for marketing purposes. However, in general we may disclose your personal information to selected third parties in order to achieve the purposes set out in this Notice. Where information is shared, only the minimum amount of information required for that purpose will be disclosed.

These parties may include (but are not limited to):

a.     The ABC and the ABC Training Trust;

b.     local government agencies;

c.     funding bodies such as Sport England and NGBs (eg. British Mountaineering Council);

d.     awarding bodies such as Mountain Training;

e.     other members of the ABC;

f.      healthcare professionals;

g.     providers of kit and equipment;

h.     suppliers and sub-contractors for the performance of any contract we enter into with them, for example IT service providers such as website hosts or cloud storage providers;

i.       professional service providers such as accountants and lawyers;

j.       parties assisting us with research to monitor the impact/effectiveness of our work, events, services and activities; and

k.     regulatory authorities, such as tax authorities;

l.       our insurers

In particular, we reserve the right to disclose your personal information to third parties:

in the event that we sell or buy any business or assets, in which case we will disclose your personal information to the (prospective) seller or buyer of such business or assets;

if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;

if we are under any legal or regulatory duty to do so; and/or

to protect the rights, property or safety of TCA/UCR, their personnel, users, visitors or others.

9.     Security/storage of and access to your personal information

TCA & UCR are committed to keeping your personal information safe and secure and we have appropriate and proportionate security policies and organisational and technical measures in place to help protect your information.

Your personal information is only accessible by appropriately trained staff, volunteers and contractors, and stored on secure servers which have features to prevent unauthorised access.

10.  International Data Transfers

Countries in the European Economic Area (“EEA”) all have the same level of data protection law as under the GDPR and, where practical, we will endeavour to use agencies and/or suppliers that operate within the EEA.

We may sometimes have a business need to use agencies and/or suppliers to process personal information on our behalf that operate outside the EEA. It is possible that personal information we collect from you will be transferred to and stored in a location outside the EEA, most typically, the United States.

Please note that some countries outside of the EEA have a lower standard of protection for personal information, including lower security requirements and fewer rights for individuals. Where your personal information is transferred, stored and/or otherwise processed outside the EEA in a country that does not offer an equivalent standard of protection to the EEA, we will take all reasonable steps necessary to ensure that the recipient implements appropriate safeguards (such as by entering into standard contractual clauses which have been approved by the European Commission) designed to protect your personal information and to ensure that your personal information is treated securely and in accordance with this Notice. If you have any questions about the transfer of your personal information, please contact us using the details below.

Unfortunately, no transmission of your personal information over the internet can be guaranteed to be 100% secure – however, once we have received your personal information, we will use strict procedures and security features to try and prevent unauthorised access.

11.  Exercising your Rights

Where we rely on your consent to use your personal information, you have the right to withdraw that consent at any time. This includes the right to ask us to stop using your personal information for marketing or fundraising purposes or to unsubscribe from our email list at any time. You also have the following rights:

a.     Right of access – you can write to us to ask for confirmation of what personal information we hold on you and to request a copy of that personal information. Provided we are satisfied that you are entitled to see the personal information requested and we have successfully confirmed your identity, we will provide you with your personal information subject to any exemptions that apply.

b.     Right of erasure – at your request we will delete your personal information from our records as far as we are required to do so. In many cases we would propose to suppress further communications with you, rather than delete it.

c.     Right of rectification – if you believe our records of your personal information are inaccurate, you have the right to ask for those records to be updated. You can also ask us to check the personal information we hold about you if you are unsure whether it is accurate/up to date.

d.     Right to restrict processing – you have the right to ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate usage.

e.     Right to object – you have the right to object to processing where we are (i) processing your personal information on the basis of the legitimate interests basis (see paragraph 4), (ii) using your personal information for direct marketing or (iii) using your information for statistical purposes.

f.      Right to data portability – to the extent required by the GDPR, where we are processing your personal information (that you have provided to us) either (i) by relying on your consent or (ii) because such processing is necessary for the performance of a contract to which you are party or to take steps at your request prior to entering into a contract, and in either case we are processing using automated means (i.e. with no human involvement), you may ask us to provide the personal information to you – or another service provider – in a machine-readable format.

g.     Rights related to automated decision-making – you have the right not to be subject to a decision based solely on automated processing of your personal information which produces legal or similarly significant effects on you, unless such a decision (i) is necessary to enter into/perform a contract between you and us/another organisation; (ii) is authorised by EU or Member State law to which TCA/UCR is subject (as long as that law offers you sufficient protection); or (iii) is based on your explicit consent.

Please note that some of these rights only apply in limited circumstances. For more information, we suggest that you contact us using the details in paragraph 14 below.

We encourage you to raise any concerns or complaints you have about the way we use your personal information by contacting us using the details provided in paragraph 14 below.  You are further entitled to make a complaint to the Information Commissioner’s Office – www.ico.org.uk. For further information on how to exercise this right, please contact us using the details below.

12.  Changes to this Notice

We may update this Notice from time to time. We will notify you of significant changes by contacting you directly where reasonably possible for us to do so and by placing an update notice on our website. This Notice was last updated on 25th April 2018.

13.  Links and third parties

We link our website directly to other sites. This Notice does not cover external websites and we are not responsible for the privacy practices or content of those sites. We encourage you to read the privacy policies of any external websites you visit via links on our website.

From time to time we may allow third parties to conduct their own activities in our centre or at events we run. Under these circumstances we accept not responsibility for any information you choose to give to such parties.

14.  How to contact us

Please let us know if you have any questions or concerns about this Notice or about the way in which TCA/UCR process your personal information by contacting us at the channels below. Please ask for/mark messages for the attention of the Data Protection Officer.

Email: dpo@theclimbingacademy.com

Telephone 0141 429 6331

Post: The Climbing Academy, 124 Portman Street, Glasgow, G41 1EJ

 

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CONSENT FORM FOR PARTICIPANTS WISHING TO USE AUTO BELAYS AT THE CLIMBING ACADEMY

FORM C:  Auto Belay Climbing 


Review The Climbing Academy's Privacy Policy

IMPORTANT BEFORE YOU BEGIN

DEFINITIONS 

  • Participants: Are those who are climbing or bouldering, or those supervising other participants climbing or bouldering.
  • Signatory: The signatory may be the participant or an individual with responsibility for the participant (see below).

THIS FORM IS TO BE COMPLETED BY INDIVIDUALS OVER THE AGE OF 16.

YOU MAY COMPLETE THIS FORM ON BEHALF OF SOMEONE UNDER 18, OR AN ADULT WHO IS OTHERWISE INCAPABLE OF UNDERSTANDING IT PROVIDED YOU ARE OVER 18 AND MEET ONE OF THE FOLLOWING CRITERIA:

  • You are the participant's legal guardian or parent
  • You are acting "in loco parentis" and have the consent of the participant's parent(s) to give consent on their behalf
  • You have power of attorney over the participant
  • You are acting as a translator, in which case the participant should still be the end signatory

PLEASE READ THE ASSOCIATION OF BRITISH CLIMBING WALLS PARTICIPATION STATEMENT

“All climbing activities have a risk of serious injury or death.  Participants must recognise that even if they follow all good practice there may still be the risk of accident and injury.  It is the responsibility of the participant to adhere to the conditions of use.”

CONDITIONS OF AUTO BELAY REGISTRATION

You have completed the TCA Registration Form (Form A1) and agree to abide by our Terms & Conditions of Use, and customer policies where relevant. - If you have not done so or have any questions, please ask a member of staff to help you.

You must agree to a series of statements set out below and then select to sign the declaration at the end of the form.

You must give satisfactory answers to a series of YES or NO questions and you will be asked to answer some competency questions by a member of staff.

Auto Belay Rules

All climbers must adhere to the rules of the centre at all times. Failure to do so will result in being asked to leave the climbing area by a member of TCA staff. If you are supervising other climbers you are responsible for them also adhering to these rules. 

A copy of our rules is available at reception, on our website and are posted throughout the centre.

CONDITIONS OF SUPERVISORY ROLE

Where the participant is over the age of 18 and is also the signatory, they may supervise up to 2 novices of any age in auto belaying and bouldering.

  • Supervising members owe a higher duty of care to under 18s than to adults of equal competence. 
  • Under 18s must remain under the supervising member's constant supervision at all times whilst on the premises. 
  • Under 18s must not engage in any climbing activity beyond their level of competence, ability or maturity nor that of the supervisor.

DECLARATION OF FITNESS

I certify that to the best of my knowledge, I do not suffer from a medical condition which might have the effect of making it more likely that I will be involved in an accident while climbing on an auto belay o bouldering or supervising anyone using an auto belay or bouldering, which could result in injury to myself or others.

I Agree

Any individual who is not capable of accepting this declaration is advised to seek medical advice before taking part or, that they use TCA Centres in a supervised capacity only. If you only intend to supervise we accept that this standard of fitness may be different to someone who intends to climb in which case please agree and answer the addendum question on the following page.

STATEMENT OF RESPONSIBILITY

I certify that, where permitted to act as a Supervisor by the Terms and Conditions of The Climbing Academy, I will accept full responsibility for any individual under my supervision and will ensure that they adhere to the Terms and Conditions and Rules.

I Agree

DECLARATION OF FACT

I also confirm that all the information I give here is correct and if any of that information changes I will notify the centre.

I Agree

First Participant's Name

First Name*

Last Name*
First Participant's Date of Birth*
First Participant's Signature*
Second Participant's Name

First Name*

Last Name*
Second Participant's Date of Birth*
Third Participant's Name

First Name*

Last Name*
Third Participant's Date of Birth*
Fourth Participant's Name

First Name*

Last Name*
Fourth Participant's Date of Birth*
Fifth Participant's Name

First Name*

Last Name*
Fifth Participant's Date of Birth*
Sixth Participant's Name

First Name*

Last Name*
Sixth Participant's Date of Birth*
Seventh Participant's Name

First Name*

Last Name*
Seventh Participant's Date of Birth*
Eighth Participant's Name

First Name*

Last Name*
Eighth Participant's Date of Birth*
Ninth Participant's Name

First Name*

Last Name*
Ninth Participant's Date of Birth*
Tenth Participant's Name

First Name*

Last Name*
Tenth Participant's Date of Birth*
Parent, Guardian or Responsible Adult's Email Address

Email
Check to receive information, news, and discounts by e-mail.
A signed copy of this waiver will be sent to the email address you provide.
Signatory: Please answer the following questions carefully by selecting "YES" or "NO".
Have you read, understood and agree to abide by, the Conditions of Use and Rules of the centre?*
Have you read the Participation Statement and do you understand that failure to exercise due care could result in injury or death?*
Do you understand the terms "auto belay" and "bouldering" and the risks associated with these activities?*
Can you put on a climbing harness correctly?*
Do you understand that failure to clip the auto belay tape to your harness correctly, or to climb while the auto belay tape is not retracting could result in your serious injury or death?*
Do you understand that the matting under the walls does not guarantee your safety?*
Do you have any questions regarding the application of the Conditions of Use or the Rules?*
If you are completing this form for someone under 18, please answer the following questions.
Is/Are the above named minor(s) under the age of 18 years?
Are you the legal guardian or parent of the named minor(s)?
Have you been given sufficient time and information to understand the risks of unsupervised auto belay climbing and bouldering?
Addendum to Declaration of Fitness
I only intend to supervise and my Declaration of Fitness applies to supervision only.*
N/A
Yes
Parent(s), legal guardian(s), carer(s), or other responsible adult must sign for any participating minor (those under 16 years of age) and agree that they and the minor are subject to all the terms of this document, as set forth above.
Parent, Guardian or Responsible Adult's Name

First Name*

Last Name*

Relationship*
Parent, Guardian or Responsible Adult's Date of Birth*
Parent, Guardian or Responsible Adult's Signature*
Electronic Signature Consent*
By checking here, you are consenting to the use of your electronic signature in lieu of an original signature on paper. You have the right to request that you sign a paper copy instead. By checking here, you are waiving that right. After consent, you may, upon written request to us, obtain a paper copy of an electronic record. No fee will be charged for such copy and no special hardware or software is required to view it. Your agreement to use an electronic signature with us for any documents will continue until such time as you notify us in writing that you no longer wish to use an electronic signature. There is no penalty for withdrawing your consent. You should always make sure that we have a current email address in order to contact you regarding any changes, if necessary.


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