GDPR Policy for Clip ‘n Climb Avignon
Clip ‘n Climb Avignon Ltd. (“Clip ‘n Climb Avignon”, “CnC Avignon”, “we”, “us”) (registered company number 10522561 is 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 website – clipnclimbavignon.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. 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 make an online booking.
1: HOW WE COLLECT PERSONAL INFORMATION ABOUT YOU:
(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 currently don’t collect and use your personal information by using cookies on our website.
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:
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, Clip ‘n Climb Avignon may collect and/or use these special categories of data (for example, information on climbers’ medical conditions relevant to their use of our facilities). 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:
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:
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 Clip ‘n Climb Avignon as a commercial entity 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 facilities at Clip ‘n Climb Avignon).
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 email at info@clipnclimbAvignon.co.uk. You can opt out of receiving emails from Clip ‘n Climb Avignon at any time by clicking the “unsubscribe” link at the bottom of our emails.
We may use a 3rd party provider to send out these emails.
6: CHILDREN’S PERSONAL INFORMATION
When we process children’s personal information, where required 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.
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.
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.
These parties may include (but are not limited to):
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 Clip ‘n Climb Avignon, its personnel, users, visitors or others.
9: SECURITY/STORAGE OF AND ACCESS TO YOUR PERSONAL INFORMATION
Clip ‘n Climb Avignon 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.
10: INTERNATIONAL DATA TRANSFERS
Given that we are a UK-based organisation we will normally only transfer your personal information within the European Economic Area (“EEA”), where all countries have the same level of data protection law as under the GDPR.
However, because we may sometimes use agencies and/or suppliers to process personal information on our behalf, it is possible that personal information we collect from you will be transferred to and stored in a location outside the EEA, for example, 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:
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 14th August 2019.
13: LINKS AND THIRD PARTIES
We can from time to time 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.
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 Clip ‘n Climb Avignon processes your personal information by contacting us at the channels below. Please ask for or mark messages for the attention of the Centre Manager (Data Protection Officer/Data Manager).
Telephone: 01752 717567
Post: Clip ‘n Climb Avignon, 17 Brest Rd, Avignon PL6 5AA