PRIVACY POLICY

Club71 respects your privacy and is committed to protecting your personal data. This privacy policy contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and how to contact us and supervisory authorities in the event you have a complaint.

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Your Consent 

By using our site, you consent to our online privacy policy.

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Who we are

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Club71 Limited (“we”, “us”) is the operator of the website www.club71.co.uk. We collect, use and are responsible for certain information about you. We are regulated under the UK Data Protection Act 2018 (DPA) and UK General Data Protection Regulation (UK GDPR) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

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The information we collect and use

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

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Contact Data includes billing address, delivery address, email address and telephone numbers.

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Financial Data includes bank account and payment card details.

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Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

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Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. 

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Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

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Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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Use of cookies

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Club71 does not use cookies. You can visit our website without submitting any personal information.

For further information on cookies generally, visit www.aboutcookies.org

 

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If you fail to provide personal data

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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 (for example, to provide you with goods or services). In this case, we may have to cancel a product you have ordered or a subscription you have with us but we will notify you if this is the case at the time. 

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How is your personal data collected?

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We use different methods to collect data from and about you. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

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• apply for our products or services;

• create an account on our website;

• leave comments on the website;

• subscribe to our service or publications; 

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us. 

 

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How is your data stored?

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Club71 website is hosted by Wix.com Ltd who can store your data in a number of locations.

Your personal information may be stored in data centres located in the United States of America, Ireland, South Korea, Taiwan and Israel. Wix.com Ltd may use other jurisdictions as necessary for the proper delivery of their services and/or as may be required by law.

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Wix is a global company that respects the laws of the jurisdictions it operates within. The processing of the User Customer Data may take place within the territory of the European Union, Israel or a third country, territory, or one or more specified sectors within that third country, of which, the European Commission has decided that it ensures an adequate level of protection (transfer on the basis of an adequacy decision). 

Important:

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Any transfer to a third country, outside the European Union, that does not ensure an adequate level of protection according to the European Commission, will be undertaken in accordance with the Standard Contractual Clauses (2010/87/EU) set out in Appendix 1 of the Wix Data Processing Agreement (DPA) 

The security of sensitive data is of extreme importance to Wix. See all the security certifications received by Wix.com. You can access Wix privacy policy in full here: https://www.wix.com/about/privacy

 

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Keeping your personal information secure

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We have appropriate security measure in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way.

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We limit access to your personal information to those who have a genuine business need to know it. Those people processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We will use technical measures to safeguard your personal data, for example:

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•  we store your personal data securely on password protected devices

• payment details are compatible with Payment Card Industry Data Security Standards (PCI DSS)

 

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.

While we will use all reasonable efforts to keep your personal data safe, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that is transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us (see ‘How to contact us’ below).

 

If you would like detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

 

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How we use your personal data

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We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

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• 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 obligation.

• Where you have opted in to receive communications from us, for example newsletters.

 

You have the right to withdraw consent to marketing at any time by contacting us.

 

Do we disclose any information to outside parties? 

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
 

Third party links 

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
 

Online Privacy Policy Only 

This online privacy policy applies only to information collected through our website and not to information collected offline.

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Data retention

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How long will you use my personal data for?

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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

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In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

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Your rights regarding your personal information:

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The European Union’s General Data Protection Regulation and other applicable data protection laws provide certain rights for data subjects. 

You have the following rights under the GDPR:

a. Right to request access to your personal data

b. Right to request correction of your personal data

c. Right to request erasure of your personal data

d. Right to object to the processing of your personal data

e. Right to request restriction of the processing of your personal data

f. Right to request the transfer of your personal data

g. Right to withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

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No fee usually required

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You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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What we may need from you

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We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

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Time limit to respond

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We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

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Further information on each of these rights is available from the Information Commissioner’s Office. If you would like to exercise any of these rights, please email, call or write to us (see ‘How to contact us’ below)

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How to Contact Us

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We hope that we can resolve any query or concern you raise about the way we use your personal information Please contact us if you have any questions about this privacy policy or the information we hold about you.

If you wish to contact us, please send an email to hello@club71.co.uk or write to us at Club71, The Quay, 30 Channel Way, Ocean Village, SO14 3TG.

The DPA also gives you the right to lodge a complaint with a supervisory authority. The supervisory authority I the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone 0303 123 1113.

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Changes to the Privacy Policy

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This Privacy Notice was published on 2nd July 2022. We may change this Privacy Notice from time to time. You should check this policy occasionally to ensure you are aware of the most recent version.

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Do you need extra help?

If you would like this policy in another format (for example: audio, large print, braille) please contact us (see ‘How can you contact us?’ above).