For the purpose of the General Data Protection Regulation ("GDPR"), we are the Data Controller of any personal data we hold regarding you. We respect your privacy and are committed to protecting this data. We adhere to the principles of the GDPR when processing your personal data.
If you have (i) any concerns about our processing of your personal data or (ii) you have a general enquiry in relation to data protection, please contact our administrator [firstname.lastname@example.org].
You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK's supervisory authority for data protection issues (www.ico.gov.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.
1. What is personal data?
Personal Data: means any information relating to an identified or identifiable natural person ("Data Subject") from which that Data Subject can be identified directly or indirectly (in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
Special Category of Data: means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.
When we refer to "personal data", we mean both personal and special category of data, although we only collect limited special category data from you if you need to provide medical information to participate in our activities (e.g. to ensure your safety on the water).
2. The data we collect about you
We primarily collect personal data from you through direct interactions with us by email, through our website (e.g. creating a user account or registering for events), social media interactions, post, telephone, or face to face.
We may collect the following data to undertake one of the services that you have requested:
- Contact information including address, postcode, email address and telephone number;
- Payment details, when you pay for membership or any other service;
- Information regarding your medical suitability to participate in events we may organise or otherwise be involved in. Note that you have the ability to decide how much or how little of this information to provide to us and we will destroy the information stored for such events within six months;
- Any data regarding how you use our website through user accounts, event registration, providing content (e.g. posts and comments on posts), and cookies that we use on our website;
- IP addresses - we may collect information (where available) about your IP (internet protocol) address, operating system and browser type. This data provides us with information about your browsing actions and patterns. It is used to inform improvements to our website and for internal system administration; and
- Any other information you email, post or otherwise send to us.
As you interact with our website, we will automatically collect technical data regarding your equipment, browsing actions and patterns. We collect this personal data by using cookies and similar technologies.
3. Where will we store your data?
Your personal data will be stored in the UK.
4. 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 (i.e. by virtue of your being, or wishing to be, a member of our club or take part in one of the events we organise) 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 a product or service you have with us but we will notify you if this is the case at the time.
5. How we use your personal data
To provide our services to you, we need to know your name and contact details. For some services, we may need additional information about you.
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:
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; and
For office administration and internal record keeping purposes.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
6. Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are (where appropriate).
We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
What we use your data for:
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a member
Performance of a contract with you.
To process and deliver your membership with us.
Performance of a contract with you.
To manage our relationship with you, which will include notifying you about changes to our website terms or privacy notice and club events.
(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation.
Providing sailing events in which non-members can participate
Medical suitability for sailing declaration
Details of medical concerns if provided
Essential to keep you safe on the water.
Sharing photographs and videos taken during club events (unless you tell us that you do not wish your picture to be shared), or provided by members.
Photographs and Videos, including of people and boats
Record of club events.
Copyright resides with the Photograph or Video taker unless otherwise stated.
To share information about the club's activities
Any content you post, comment or otherwise provide on our website
Performance of a contract with you.
Cookies through our website.
Technical data regarding your equipment, browsing actions and patterns.
We ask you to provide consent for all non-essential cookies that we use on our website.
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 contact us.
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.
7. Disclosures of your personal data
We may disclose your personal data to third parties:
in the event that we merge with any other organisation or sell or buy any business or assets, in which case, we may disclose your personal data to the prospective seller or buyer of such business or assets;
if we or substantially all of our assets are acquired by a third party, in which case, personal data held by us about you will be one of the transferred assets;
to protect the rights, property, or safety of us or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. Note that this is only done with your explicit consent when concerning medical information and this information will only be shared with a potential skipper who may be responsible for your safety on the water.
In all instances where we disclose your personal data to third parties, we will ensure that your data is appropriately protected.
Where our suppliers process our personal data on our behalf, we require them to put in place appropriate security measures to protect your personal data in line with our policies. We do not allow our suppliers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, in accordance with our instructions and data protection law.
8. International transfers
We do not transfer your personal data outside the European Economic Area (the "EEA").
9. Is your personal data safe?
We work hard to protect your personal data and have adopted appropriate technical and organisational measures to prevent it from being accidentally lost, used or accessed in an unauthorised way, altered or destroyed.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us via the internet. Any transmission is at your own risk.
10. Data retention
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 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 of our relationship with you.
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.
Our policy is to retain your personal data for no more than two years after the end of the financial year during which you cease to be a member or first made contact with us to become a member, whichever is the later.
We will only store medical information provided to us for a period of six months after the event for which it was provided.
We use traffic log cookies to identify which pages are being used and provide website statistics. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
12. Your legal rights
Under certain circumstances, you have rights under data protection law in relation to your personal data. We have summarised your rights below:
You can request access to your personal data.
You can seek to restrict our processing of your personal data or ask us to rectify any personal data we hold about you.
You can object to us processing your personal data where we are relying on legitimate interest and we will cease processing for the purpose you object to. An exception to this would be where we have compelling legitimate grounds for processing which override your interests, rights and freedoms or where it is necessary for the establishment, exercise or defence of legal claims.
You have the right to ask us to provide you with your personal data in a structured, commonly used and machine-readable format to allow you (or us on your behalf) to transmit this information to another party. More information can be found at www.ico.org.uk.
You have the right to ask for the data held about you to be corrected. Please help us keep our records updated by informing us of any changes to your personal data.
You have the right to ask us to erase the personal data we hold about you. Such circumstances include: (a) where we no longer need your personal data for the purposes set out above; (b) if you withdraw your consent to our processing; (c) if you object to our processing based on our legitimate interest and we have no overriding legitimate grounds to continue processing your personal data; (d) if we process the data unlawfully; or (e) where the personal data has to be erased to comply with legal obligation to which we are subject. We will consider any such request in line with data protection law. Please note this is not an absolute right and there may be circumstances where we choose not to delete all of the personal data we hold about you. More information about your right of erasure can be found at www.ico.org.uk.
If you would like to exercise any of the rights set out above, please contact our administrator [email@example.com].
13.Third party links
Specifically, our website is hosted by Fast2Host (see https://www.fast2host.com/legal/privacy-policy) and Sailing Club Manager (see https://www.sailingclubmanager.com/terms/privacy-policy and https://www.sailingclubmanager.com/terms/gdpr). Any information you share via our social media accounts is covered by those policies.
14. Changes to our privacy notice
Last updated 14:22 on 17 May 2023