The Climbing Hub - Privacy Policy
1. Introduction
The Climbing Hub Ltd is committed to protecting your privacy.We aim to respect any personal information you share with us, or that we receive from others, and keep it safe at all times. 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 website–www.theclimbinghub.co.uk
This Notice contains important information about your personal rights to privacy. Please read it carefully to understand how we use your personal information.
Whilst the provision of your personal information to us is voluntary,withholding your personal information from us may prove to limit/impair our services or your interaction with us. For example, you may be unable to sign up as a member.
2. Scope
All data subjects whose personal data is collected, in line with the requirements of the GDPR.
3. Responsibilities
3.1- The Data Protection Officer is responsible for ensuring that this notice is made available to data subjects prior to the collecting/processing of their personal data.
3.2- All Employees/Staff or External Instructors of The Climbing Hub organisation who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.
4. Privacy Notice
4.1- Who are we?
The Climbing Hub is a Bouldering and Climbing centre based in Bradford. We aim to provide the latest and best training facilities for climbers of all abilities across Bradford and the local areas, as well as customers who may be visiting from further afield. We’re passionate about being all inclusive and allowing climbing to be accessible to everyone.
Our Data Protection Officer and data protection representatives can be contacted directly here:
4.2- We collect personal information about you:
a. When you give it to us directly-
For example, personal information that you submit through our website such as pre-registering on our database; or by making a booking to use our facilities; or via our tablets at The Climbing Hub reception; 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:
4.3- We may collect, store and otherwise process the following kinds of personal information:
i) your name and contact details including postal address, telephone number, email address, emergency contact details and, where applicable, social media identity;
ii) your date of birth and gender;
iii) your financial information, such as bank details and/ or credit/ debit card details,
iv) information about your computer/ mobile device and your visits to and use of this website, including, for example, your IP address and geographical location;
v) personal descriptions and photographs;
vi) details of your qualifications/ experience;
vii) CCTV images
viii) Information relating to accidents or medical emergencies on the premises
ix) Medical information where you feel it would be appropriate to inform us of a medical condition
and/ or any other personal information which we obtain as per paragraph 4.2.
4.4- The personal data we collect, depending on the role, will be used for the following purposes:
- To register you as a member of The Climbing Hub;
- Identification of customer on visiting the centre;
- To allow you to make a booking to use our facilities;
- Contacting named emergency contacts in the event of an emergency
- To otherwise provide you with services, products or information you have requested;
- To provide further information about our work, services or activities (where neccessary, only when you have provided your consent to recieve such information);
- To assist you with certification schemes, such as NIBAS;
- To answer your questions/ requests and communicate with you in general;
- To allow you to apply for a job or volunteer role with us;
- To manage relationships with our partners and service providers;
- To analyse and improve our work, services, activities, products or information (including our wesbite), or for our internal records.
- To keep our facilities safe and secure;
- Emergency Evacuation
- To run/administer the activities of The Climbing Hub,including our website, and ensure that content is presented in the most effective manner for you and for your device;
- To audit and/ or administer our accounts;
- 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);
- For the prevention of fraud or misuse of services; and/or
- For the establishment,defenceand/ or enforcement of legal claims.
- Verifying identity for payments processed by Stripe (www.stripe.com) on our behalf. This happens once permission has been given by the customer.
Our legal basis for processing for the personal data (Article 6(1b));
4.5- Consent
You are giving The Climbing Hub Ltd permission to process the personal data supplied specifically for the purposes identified. The Climbing Hub Ltd collects data under the terms identified in Article 6 ‘Lawfulness of processing’ of the General Data Protection Regulation.
Where consent is required for The Climbing HubLtd to process personal data, it must be explicitly given.
You may withdraw consent at any time by contacting the Data Protection Officer atThe Climbing Hub using the contact details above.
4.6- Disclosure
The Climbing Hub Ltd will not release the information to any third party unless the request is subject to legal obligation without obtaining the express written authority of the partner who provided the information.
4.7- Retention period
We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies.
For more information on storage and processing security, please contact The Climbing Hub Ltd using the details above.
4.8- Your rights as a data subject
At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:
All of the above requests will be dealt with in line withThe Climbing Hub Ltd’s Subject Access Procedure and will shared with the customer should a request come from directly a subject.
4.9- How do we protect your Personal Information?
We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption.
The Climbing Hub is 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.
4.10- Third parties
We use several third parties to process and administer customer information. We only use companies who show full compliancy with the GDPR legislation.
Source - What we use them for - GDPR Compliant
Rock Gym Pro - Entry system and database storage on US servers - Yes (US privacy Shield)
Sagepay - Website Shop Payments - Yes
Stripe - Website online bookings and e-billing monthly payments - Yes (US privacy Shield)
Sendgrid - Automated emails from Rock Gym Pro and newsletter mailouts - Yes (US privacy Shield)
Worldpay - PDQ terminal transactions within thecentre - Yes
ABC/NIBAS - Registration for the NIBAS scheme - Yes
4.11- Cookies
INFORMATION COLLECTED AUTOMATICALLY
Whenever you interact with any part of our Website, we automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. “Cookies” are identifiers we transfer to your computer or mobile device that allow us to recognize your browser or mobile device and tell us how and when pages in our Website are visited and by how many people. The usage information we gather automatically from the Website will always be used in aggregate and never in a way that is personally identifiable.
4.12- Complaints
If you wish to make a complaint about how your personal data is being processed byThe Climbing Hub Ltd or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and schools/organisation’s data protection representatives.
The details for each of these contacts are:
Supervisory authority contact details:
Contact Name: Information Commissioners Office
Address Line 1: Wycliffe House
Address Line 2: Water Lane
Address Line 3: Wilmslow
City:
County: Cheshire
Postcode: SK9 5A
Email: Registration@ico.org.uk
Telephone: 0303 123 1113
Data Protection Officer contact details:
Contact Name: Ejaz Hussain
Address Line 1: The Climbing HubLtd.
Address Line 2: 10-13 Beckside Business Park
Address Line 3: BecksideRoad
City: Bradford
County: West Yorkshire
Postcode: BD7 2BR
Email: Info@theclimbinghub.co.uk
Telephone: 01274 270 123