Privacy & Cookie Policies

Privacy Policy

Background

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data. This privacy notice applies to personal information processed by or on behalf of Dacorum Sports Trust and any subsidiaries of this Registered Charity.

Changes to this privacy notice

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website.

What data do we collect?

Personal information that we’ll process in connection with all of our products and services, if relevant, includes:

Personal and contact details, such as title, full name, contact details and contact details history
Your date of birth, gender and/or age
Your nationality, if needed for the product or service
Family members (if relevant to the product or service)
Records of your contact with us such as via a phone number, if you get in touch with us online using our online services or via our Mobile app, details such as your mobile phone location data, IP address and MAC address
Products and services you hold with us, as well as have been interested in and have held and the associated payment methods used.
The usage of our products and services, (Such as attendance visits logged by access control)
Marketing to you and analysing data, including history of those communications, whether you open them or click on links, and information about products or services we think you may be interested in, and analysing data to help target offers to you that we think are of interest or relevance to you. Offers may include our Golf Products, Birthday Parties products, Charitable donations, Fitness products/services and any of our other products and services
Information we obtained from third parties
Personal information which we obtain from Credit Reference Agencies and Fraud Prevention Agencies (see the section on ‘Fraud Prevention Agencies’ below), including public (for example, defaults, CCJs) and shared credit history, financial situation and financial history
Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud
Information about your health or if you are a vulnerable customer
Information about your employment status, if relevant
Your marital status, family, lifestyle or social circumstances, if relevant to the product (for example, the number of dependents you have or if you are a widow or widower)
Information we buy or rent from third parties, including demographic information, marketing lists, publicly available information, and information to help improve the relevance of our products and services
Insights about you and our customers gained from analysis or profiling of customers
Third party transactions; such as where a person other than the account holder uses the service, information about that person and the transaction

What is the source of your personal information?

We’ll collect personal information from the following general sources:

From you directly, and any information from family members, associates or beneficiaries of products and services.
Information generated about you when you use our products and services.
Business partners (for example, financial services institutions, insurers), account beneficiaries, or others who are a part of providing your products and services or operating our business.
From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, HMRC, DWP, publically available directories and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies
We buy or rent information about you or customers generally from third parties including demographic information, fraud information, marketing lists, publicly available information and other information to help improve our products and services or our business

What do we use your personal data for?

We use your personal data for the following purposes:

Assessing an application for a product or service, including considering whether or not to offer you the product or service, the price, the risk of doing so, availability of payment method and the terms.
Managing products and services relating to that the product or service, or application for one.
Updating your records, tracing your whereabouts and recovering debt.
Managing any aspect of the product or service.
To make automated decisions on whether to offer you a product or service, or the price, payment method, risk or terms of it
To perform and/or test the performance of, our products, services and internal processes
To improve the operation of our business
For management and auditing of our business operations including accounting
To monitor and to keep records of our communications with you and our staff (see below)
For market research and analysis and developing statistics
For direct marketing communications and related profiling to help us to offer you relevant products and service, including deciding whether or not to offer you certain products and service. We’ll send marketing to you by SMS, email, phone, post, social media and digital channels (for example, using Compaign Monitor). Offers may relate to any of our products and services such as Memberships, Birthday party products, Golfing products, member offers (“Member Benefits”) as well as to any other offers and advice we think may be of interest.
To provide personalised content and services to you, such as tailoring our products and services, our digital customer experience and offerings, and deciding which offers or promotions to show you on our digital channels.
To develop new products and services and to review and improve current products and services
To comply with legal and regulatory obligations, requirements and guidance.
To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses.
To process any donations made to Absolutely Together.

What are the legal grounds for our processing of your personal information
(including when we share it with others)?

We rely on the following legal bases to use your personal data, where it is needed to provide you with our products or services, such as:

Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product, the price, the payment methods available and the conditions to attach.
Managing products and services you hold with us, or an application for one.
Updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate).
All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts, illustrations, requests for transfers of equity, setting up/changing/removing guarantors.
For some of our profiling and other automated decision making to decide whether to offer you a product and/or service, particular payment method and the price or terms of this.

Where it is in our legitimate interests to do so, such as:

Managing your products and services relating to that, updating your records, tracing your whereabouts to contact you about your account and doing this for recovering debt (where appropriate).
To perform and/or test the performance of, our products, services and internal processes.
To follow guidance and recommended best practice of government and regulatory bodies.
For management and audit of our business operations including accounting
To carry out monitoring and to keep records of our communications with you and our staff (see below).
For market research and analysis and developing statistics
For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by SMS, email, phone, post and social media and digital channels.
Subject to the appropriate controls, to provide insight and analysis of our customers to business partners either as part of providing products or services, helping us improve products or services, or to assess or to improve the operating of our businesses.
For some of our profiling and other automated decision making.l) Where we need to share your l) personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations.
To comply with our legal obligations

With your consent or explicit consent:

For some direct marketing communications
For some of our profiling and other automated decision making
For some of our processing of special categories of personal data such as about your health, if you are a vulnerable customer or some criminal records information

For a public interest, such as:

Processing of your special categories of personal data such as about your health, criminal records information (including alleged offences), or if you are a vulnerable customer

When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

Business partners (for example, financial services institutions, insurers), account beneficiaries, or others who are a part of providing your products and services or operating our business
Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme
Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions
Credit Reference and Fraud Prevention Agencies (see below)
Market research organisations who help us to develop and improve our products and services

How and when can you withdraw your consent?

Where we’re relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

Is your personal information transferred outside the UK or the EEA?

We’re based in the UK but sometimes your personal information may be transferred outside the European Economic Area. If we do so we’ll make sure that suitable safeguards are in place, for example by using approved contractual agreements, unless certain exceptions apply.

What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section. We’ll then update your records if we can.

Do you have to provide your personal information to us?

We’re unable to provide you with our products or services if you do not provide certain information to us. In cases where providing some personal information is optional, we’ll make this clear.

Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we’ll do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

What about other automated decision making?

We sometimes make decisions about you using only technology, where none of our employees or any other individuals have been involved. For instance, we may do this to decide: whether to offer you a product or service, to determine the risk of doing so, the price we will offer, whether to offer you credit, what terms and conditions to offer you, assess lending, insurance and business risks, or to assess what payment methods we can offer you.

We’ll do this where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent.

For how long is your personal information retained by us?

Unless we explain otherwise to you, we’ll hold your personal information based on the following criteria:

For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
Retention periods in line with legal and regulatory requirements or guidance.

What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They don’t apply in all circumstances. If you wish to use any of them, we’ll explain at that time if they are engaged or not. The right of data portability is only relevant from May 2018.

The right to be informed about the processing of your personal information
The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
The right to object to processing of your personal information
The right to restrict processing of your personal information
The right to have your personal information erased (the “right to be forgotten”)
The right to request access to your personal information and to obtain information about how we process it
The right to move, copy or transfer your personal information (“data portability”)
Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you

You have the right to complain to the Information Commissioner’s Office which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.

Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the ‘Contact Us’ section of our website to exercise these rights.

What are your marketing preferences and what do they mean?

We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook, Google and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.

Contact Us

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the Data Protection Officer, you can contact us by going to the ‘Contact Us’ section of our website. Alternatively, you can write to Dacorum Sports Trust, The Arena, Stafferton Way, Maidenhead, Berkshire, SL6 1AY, marking it for the attention of the Data Protection Officer.

Cookies

Our websites use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse the websites and also allows us to improve our websites. For detailed information on the cookies we use and the purposes for which we use them, please see our cookie policy.

Visitors to our websites

When someone visits our websites we use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. We do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We will make it clear when we collect personal information and will explain what we intend to do with it.

People who use our LiveChat service

We use a third party provider to supply and support our LiveChat service, which we use to handle customer enquiries in real time. If you use the LiveChat service we will collect your name, email address and the contents of your LiveChat session. This information will be retained for two years and will not be shared with any other organisations. You can request a transcript of your LiveChat session if you provide your email address at the start of your session or when prompted at the end.

Third Party Websites And Apps

Our websites may contain links to and from third party websites and we may provide you with details of apps provided by third parties. Please note that if you follow a link to any of these websites or download an app, these websites and apps will have their own terms of use and privacy policies and we do not accept any responsibility of liability for these policies. Please check these policies before you submit any personal data to these websites or apps.

Cookie Policy

We use cookies and similar technologies on our web sites to improve performance and make your experience better.

Your use of our web sites indicates your consent to the cookies described in this policy. Please see HOW YOU CAN CONTROL COOKIES, below, for more information on how to withdraw your consent at any time.

WHAT ARE COOKIES?

A web cookie, a commonly used data collection technology, is simply a piece of text which can be placed on the browser of your personal computer or mobile device and subsequently read as you visit a web site. A cookie may be a session cookie, that is, a cookie that remains on your browser while you are logged on to a particular web site and then disappears when you close your browser, or it may be a persistent cookie, a cookie that remains on your browser over a period of time. Information from a cookie may be collected and used in aggregate form or data may be collected into an individual profile or record. That individual record may either be unique but anonymous, or the profile can be linked with information that identifies you as an individual.

You can learn more about cookies, generally, at www.allaboutcookies.org

HOW DO WE USE COOKIES?

We may use cookies for a number of purposes:

1. Essential cookies

We may use a limited number of cookies essential to particular services you have requested or for security purposes. A few of our sites use a cookie for a shopping cart function when you purchase services or offerings. In particular, if you have registered for a site or use a customer portal we may use a cookie to authenticate the pc or mobile device that you are using.

2. Performance cookies

We allow third parties to set analytics, or performance, cookies to collect and report aggregate information. These cookies provide reporting to us on an aggregate basis and so, do not identify you at all. We use the aggregate reports to understand how our web sites are used and improve their usefulness to our audiences.

3. Functional cookies

A number of cookies also support how our web sites function, identifying your pc or end device on a unique but anonymous basis. These cookies may, for example, remember your language preferences or recognise an individual’s activity within a single session.

If you register for a site, we use a cookie to associate your presence with a specific user name and password or account. We may use a persistent cookie to recognise you automatically each time you return, but only if you ask us to do so. We may also use cookies to prepopulate your login or forms you fill out on the site with information you have already provided.

We may conduct analyses of user traffic to measure the use of our sites and to improve the content of our web sites and our services. These analyses will be performed through the use of IP addresses and cookies.

We use web beacons and pixels in our emails to track delivery and open rates. Our email provider delivers cookies with our email to recognise a user’s response. The results are stored and reported on against the individual’s email address and the account profile within our database.

The cookies we use or allow are an accepted part of ecommerce and important to your use of our web sites. Performance cookies allow us to understand our audiences as a whole and improve how our sites meet your needs and expectations. Many of the functional cookies are basic to how our sites and services work. The cookies we use for registration allow us to conduct our business online. Our sites and services, or parts of them, may not work properly without these cookies.

1. Browser controls

Most modern browsers offer you ways to control or block cookies. These browser controls will usually be found in the “options’ or “preferences” menu. For more help, you may take a look at the “Help” settings or review this website for more details – https://www.aboutcookies.org/

2. Ad cookies and targeting

You can find more information or turn off targeting by member companies at YourOnlineChoices UK, https://www.youronlinechoices.com/uk/

If our use of cookies changes, we will post the changes to this policy. Please check frequently as online data collection practices and our use of them continue to evolve. To contact us about this policy, you may email b.doe@absolutely-group.co.uk. When emailing please indicate which of our sites you question relates to.