Welcome to Tremorfa Property Limited's privacy notice. This is the company that operates the club.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
We are part of a group of companies owned by Tremorfa Group Limited (company number 06209568) whose registered office is at St Mellons Hotel, The Terrace Suite, Castleton, Cardiff CF3 2XR. This privacy policy is issued on behalf of the Tremorfa Group so when we mention “Tremorfa”, “the club”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Tremorfa Group responsible for processing your data.
You have the right 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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in December 2019 and maybe updated by us at any time.
2. THE DATA WE COLLECT ABOUT YOU
· Identity & contact data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, photograph, emergency contact details, address, email address and telephone numbers.
· Payment data includes whether or not you are up to date with your payments.
· Usage Data includes information about how often you attend the club, what services you book, whether you bring guests with you and images on CCTV.
· Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect Special Categories of Personal Data about you by collecting information about your health. We may also collect details about your child so that we can keep records of their attendance, emergency contact details and health information. We do not collect any other Special Categories of Personal Data, nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
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. In this case, we may have to cancel our contract with you 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 Payment Data by subscribing to the mobile app, on your application form to become a member or by corresponding with us by post, phone, email or otherwise.
· Automated technologies or interactions. As you interact with our mobile app and book any club session or swipe your card/mobile app to enter the club, we may automatically collect data.
· Information form third parties. If your membership at the club is through your employer, then your employer may provide us with information about you.
4. HOW WE USE YOUR PERSONAL DATA
· 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.
Purposes for which we will use your personal data: We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
· Identity & contact data: we keep this information in order to contact you in the event of issues arising at the club, to verify you as a member of the club, and to contact people on your behalf in the event of an emergency. Our lawful basis for processing this information is to perform our contract with you and to protect our legitimate business interests.
· Payment data: we keep this information in order to ensure that you are up to date with your payments. Our lawful basis for processing this information is to perform our contract with you and to protect our legitimate business interests.
· Usage Data: we keep usage information to keep a record of what services you use at the club, to manage bookings, what services are popular amongst members generally, how many guests you sign in, what services you have booked. We also retain CCTV footage for the prevention and detection of crime and health and safety issues for our members, guest and staff. Our lawful basis for processing this information is to perform our contract with you and to protect our legitimate business interests.
· Special Categories of Personal Data: we keep information about your health (and that of your child or children where appropriate) to ensure that we are aware of any health issues. We will not share this information with any other party. Our lawful basis for processing this information is to perform our contract with you and to protect our legitimate business interests. As this is Special Category Data we also rely processing this to carry out our legitimate activities; to establish, exercise or defend legal claims and for the purposes of health & safety management.
Marketing / Third-party marketing: We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We will only send you marketing material where you have confirmed you wish to receive the same on your application form or on the mobile app preferences. We will get your express opt-in consent before we share your personal data with any company outside our group of companies for marketing purposes.
Opting out: You can ask us or third parties to stop sending you marketing messages at any time by updating your preferences on the mobile app or contacting by contacting us using the details set out in Section 1 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 a service purchase, service experience or other transactions.
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 contacting us using the details set out in Section 1 above.
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
· Internal Third Parties as set out in the Glossary in Section 10 below.
· External Third Parties as set out in the Glossary in Section 10 below.
· 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 all 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.
We do not transfer your personal data outside the European Economic Area.
How long will you use my personal data for?
· 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
If you wish to exercise any of the rights set out above, please contacting us using the details set out in Section 1 above.
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 using the details set out in Section 1 above.
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.
· ClubRight who collect information on our behalf via the mobile app. Users can choose to opt out and limit data provided when signing up to the app.
· The Harlands Group who deal with financial transactions of all members for us. Harlands will take the Direct Debit of all members on the closest working day to the start of each month. All membership issues will need to contact Harlands should members wish to suspend or cancel their membership or amend their bank information.
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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.