Rockcity Sports Club CIC Privacy Policy
1. Introduction
1.1 We are committed to safeguarding the privacy of our club members and service users; in this policy we explain how we will handle your personal data.
1.2 In order to run a community amateur sports club, it is necessary to collect, store and process personal data relating to club activities for either our legal duty or where it is in our legitimate interest. A full explanation of how we do this is outlined in this policy.
1.3 Our membership system app incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you consent to receive direct marketing communication. You can access the privacy controls via the Rock Gym Pro App available on your mobile devices App Store.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 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. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data] ("account data"). The account data may include your name and email address. The source of the account data is you/parent or guardian. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our club membership system website and facilities.
2.4 We may process your information included in your personal profile on our website ("profile data").[ The profile data may include your name, address, telephone number, email address, profile pictures, gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of club membership system, website and facilities. The legal basis for this processing is our legitimate interests, namely the proper administration of our club membership system, website and facilities.
2.5 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include you IP address. The source of the service data is you/parent or guardian. The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our club membership system, website and facilities.
2.6 We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our club membership system, website and facilities.
2.7 We may process information contained in any enquiry you submit to us regarding products and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our store or website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of club membership system, website and facilities.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.10 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence 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. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our club membership system, website, facilities and communications with users.
2.11 We may process any of your personal data identified in the other provisions of this policy 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.
2.12 We may process information contained in or relating to any participation and activity relating to the sports facilities (“activity data”). This data may include gender, postcode, age, specific activity, frequency and duration of activity. The source of this data is the club membership system. This data may be processed for the purposed of enabling and administering club facilities and the promotion of participation within these sports. The legal basis for this processing is our legitimate interests, namely the proper administration of clubs and provision of its facilities.
2.13 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of 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.
2.14 Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of Rockcity group of companies insofar as reasonably necessary for the purposes set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.
3.3 We may disclose activity data to National Governing Bodies or Sports Councils and Award Scheme Provider insofar as reasonably necessary for recording national participation statistics.
3.4 Financial transactions relating to our club facilities and services may be handled by our payment services providers, Stripe, Elavon and Sagepay. 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:
https://www.sagepay.co.uk/policies/privacy-policy
https://www.elavon.co.uk/cookie-policy-and-privacy-pledge.html
https://stripe.com/fr/privacy
3.5 We may disclose your enquiry data to any member of Rockcity group of companies of goods and services identified on the Rockcity website (rockcity.co.uk) for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such Rockcity company will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such Rockcity company will be responsible for the supply a copy of its own privacy policy, which will govern that third party's use of your personal data.
3.6 In addition to the specific disclosures of personal data set out in this Section 3, we may also 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.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated in the United Kingdom.
4.3 Rockgympro and smartwaiver are situated in The United States of America. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to the United States of America will be protected by appropriate safeguards, namely Privacy Shield Certification adopted or approved by the European Commission.
4.4 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.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 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.
5.3 We will retain and delete your personal data as follows:
(a) All personal data will be retained for a maximum of 20 years following from your most recent club membership renewal, at the end of which period it will be deleted from our systems.
The legal basis for this retention is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
5.4 Notwithstanding the other provisions of this Section 5, 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.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email.
7. Your rights
7.1 In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy is subject to the payment of a fee (currently fixed at GBP 10), additional copies may be subject a reasonable fee.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8. Our details
8.1 The club is owned and operated by Climb Skate BMX C.I.C
8.2 We are registered in England and Wales under registration number 112 168 57 and our registered office is at Rockcity, Hawthorn Avenue, Hull, HU3 5GL
8.3 Our principal place of business is at (as above)
8.4 You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
9. Data protection officer
9.1 Our data protection officer's contact details are:
Rebecca Mincher
GDPR@rockcity.co.uk