Privacy & Data Protection Policy

 

 

Data Protection Law

 

From 25th May 2018, the EU General Data Protection Regulation 2016/679 (GDPR) replaced the Data Protection Act 1998. It is supplemented by the Data Protection Act 2018. We refer to these as “data protection law”.

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Data protection law regulates the processing of "personal data" relating to individuals by organisations (known as "data controllers").

 

This privacy policy provides information about how the International Jaguar XK Club handles and processes your personal information as the "data controller" & "data processor". 

 

It is important that the personal information we hold about you is accurate and current.  Please keep your personal information updated during your relationship with us.

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What personal information do we collect and how do we use it?

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Our primary goal in collecting personal information from you may be to:

• verify your identity

• help us deliver our services

• improve & develop services

• carry out requests made by you on the website or in relation to our services

• investigate or settle inquiries or disputes

• comply with any applicable law, court order, other judicial process, or the requirements of a regulator

• enforce our agreements with you

• protect the rights, property or safety of us or third parties, including our other clients and users of the website or our services

• provide support for the provision of our services; use as otherwise required or permitted by law.

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To undertake these goals we may process the following personal information:

• name (if an enquiry form is filled out - may include both first and last names)

• contact data includes billing address, email address and telephone number

• transaction data includes details about payments to and from you and other details of products and services you have purchased from us, or Club events you have attended

• IP address

• other information relevant to provision of services

• information that you provide to us as part of our providing the services to you which depends on the nature of your instruction

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Fulfillment of Services

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We collect and maintain personal information that you voluntarily submit to us during your use of the website and/or our services to enable us to perform the services. Please note also that our Terms & Conditions also apply when we provide the service.

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Who do we share your personal information with for this purpose?

We may share personal information with third parties as necessary when providing the following services:

• experts (for example, tax, accountants)

• IT & website service providers 

• event organisers

• postal service & couriers

• Club Area Representatives (see 'Third Parties' below)

• payment Solutions Limited t/a Smart Debit (when you sign up to Direct Debit with us - https://www.smartdebit.co.uk/privacy/)

 

Please note: there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.  We will inform you of how your data is being shared where applicable.

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What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest or a third party’s legitimate interest to use the personal information to ensure we provide the services in the best way that we can.

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Customer/Member services

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Our website uses a number of site forms to allow you to request information about our services. This information that is relevant to your enquiry. This information is used in order to enable us to respond to your requests.

Who do we share your personal information with for this purpose?

Your contact information is stored in our website and is deleted from the system after 90 days.  After that period the information is held securely for the appropriate time-frame depending on your type of communication with us (see data retention information)

What is our legal basis?

It is in our legitimate interest or a third party’s legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you and others.

 

Business administration and legal compliance

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We may use your personal information for the following business purposes:

• to comply with our legal obligations

• administration purposes

• to sign you up as a member of the International Jaguar XK Club

• to enforce our legal rights

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Who do we share your personal information with for these purposes?

Your information will be passed on to third parties in order to send out your printed and/or digital versions of the XK Gazette and to post/courier any other items relating to your Club membership

 

What is our legal basis?

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Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party’s legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.  It is also to fulfill a contract between the International Jaguar XK Club and you.

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Recruitment

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We use your personal information for the following recruitment purposes:

• to assess your suitability for any position for which you may apply at the International Jaguar XK Club, training contract or summer placements and also any business support or services role whether such application has been received by us online, via email or by hard copy or in person application.

• to review the International Jaguar XK Club's equal opportunity profile in accordance with applicable legislation.  The International Jaguar XK Club does not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment related decisions are made entirely on merit

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Who do we share your personal information with for these purposes?

We will share your personal information with third parties who assist us in carrying out our recruitment activity.   

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What is our legal basis?

Where we use your personal information in connection with recruitment it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions for the International Jaguar XK Club.  We will not process any special data except where we are able to do so under applicable legislation or with your explicit consent.

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Customer/Member insight and analysis

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We analyse your contact details with other personal information that we observe about you from your interactions with our Site, our email communications to you and/or with our Services.

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Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Site, or from your mobile device. This includes the following:

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• an IP address to monitor site traffic and volume

• a session ID to track usage statistics on our site

• our web pages contain ‘cookies’ (for further information on cookies we use and how to remove them please read our cookie policy).  Cookies allow us to monitor visitor interaction on our website

• our e-mails contain “cookies” "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag. In some of our e-mail messages, we use a “click-through URL” linked to a relevant page on this website

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Please see our Cookie Policy for further information on cookies we use.

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By using this information, we are able to measure the effectiveness of our content and how visitors use our site and our services. This allows us to learn what pages of our website are most used by our visitors and which parts of our site are of the most interest to them.

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Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers to assist us with visitor insight analytics. These providers include Google Analytics and Mailchimp for our email analytics.

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What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws (GDPR). However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

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Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other visitors & Club members.

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Marketing communications

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We carry out the following marketing activities using your personal information:

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Postal marketing

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From time to time we use names and addresses to send our Club members marketing communications by post.

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Our postal marketing will include personalised marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, this particular marketing will feature services that we think are most likely to appeal to you.

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Where we are sending you personalised postal marketing, we use information that we have about you from your various interactions with us via, website, email, telephone, in person at event, or other, with our email communications to you and/or with our services in order to decide what sort of personalised marketing communications to send you.

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Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party postal providers who assist us in delivering our postal marketing campaigns to you.

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What is our legal basis?

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing.

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Email marketing

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We use your name and email address to send you marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful basis to do so.

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Our email marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature those of our services that we think are most likely to appeal to you. Non-personalised marketing is marketing about our services generally and is not tailored to any particular individual.

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Where we are sending you personalised email marketing, we will also use information that we observe about you from your interactions with our website, with our email communications to you and/or with our services in order to decide what sort of personalised marketing communications to send you.

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If you ask us to remove you from marketing correspondence, we will retain your personal data for your continued Club membership and we will no longer send you marketing material.

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Who do we share your personal information with for these purposes?

We share your personal information with our third party email marketing providers (Mailchimp) who assist us in delivering our email marketing campaigns to you.

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What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

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Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, unless you are a member of the International Jaguar XK Club and in this case it is in our legitimate interest to send you marketing information in relation to our Club events and services, or where we have a lawful right to do so.

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If you wish to change your preferences with regard to what communication you receive from us please contact info@xkclub.com and provide us with information about the marketing communications you would like/would not like to receive from us.

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Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

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How do we obtain your consent?

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Where our use of your personal information requires your consent, you can provide such consent:

• at the time we collect your personal information following the instructions provided; or

• by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy

 

 

Our use of cookies and similar technologies

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Our Site uses certain cookies, pixels, beacons, scripts, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

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Third Party contractors and other controllers

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As mentioned above, we may appoint sub-contractor data processors as required to help us to deliver the Services, such as:

• club event organisers

• IT services & hosting providers

• IT support

• couriers

• merchandise suppliers

• Club Area Representatives (see below)

• Payment Solutions Limited t/a Smart Debit (when you sign up to Direct Debit with us - https://www.smartdebit.co.uk/privacy/)

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These organisations act on our behalf in accordance with our instructions and do not process your data for any purpose over and above what we have asked them to do.. We conduct an appropriate level of due diligence and put in place necessary contractual documentation in relation to any sub-contractor to ensure that they process personal information appropriately and according to our legal and regulatory obligations.

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Further, we may appoint external data controllers in common with us where necessary to deliver the services. Where we do so, we will comply with our legal and regulatory obligations in relation to the personal information including but without limitation (where necessary) putting appropriate safeguards in place to ensure any personal information is processed according to our legal and regulatory obligations.

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We do not share your data with external organisations for marketing their products or services.  We do not sell your personal data to third parties under any circumstances, or allow third parties to sell on the data we have shared with them.

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Club members are assigned to a local Area Representative (where applicable), on joining the Club.

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These Representatives have access to a limited amount of member data so that they can contact 'their' members about local news and events.

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We have investigated a full review of data protection procedures with our Representatives to ensure they are all cognisant of privacy requirements.

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As one of our aims is to maintain a sense of community between members, and encourage social activities on a regional, national and international basis, this sharing of restricted member data is a legitimate Club interest.

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Data Transfer to countries outside the EEA

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Please note that, where necessary to deliver the services, we will transfer personal information to countries outside the EEA. Not all countries provide the same level of protection in relation to personal information as within the EEA. Where necessary to make such transfers, we will comply with our legal and regulatory obligations in relation to the personal information. This will include having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information.

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Data Retention (how long do we store your data for?)

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Regarding visitors to our site, we will retain relevant personal information for at least 12 months from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world), or for longer where we are required to do so according to our regulatory obligations or professional indemnity obligations.

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Regarding personal information we have processed as part of providing the services to our club members, advertisers, sponsors, charities, we will retain relevant personal information for seven years from the date of our last interaction and in compliance with our obligations under the EU General Data Protection Regulation (GDPR) or for longer where we are required to do so according to data protection legislation.  See our Terms & Conditions for further details.

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If personal information is only useful for a short period e.g. for specific marketing campaigns, we may delete it.

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Confidentiality and security of your personal information

 

We are committed to keeping the personal information provided to us secure and we will take reasonable precautions to protect personal information from loss, misuse or alteration.

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We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access

• improper use or disclosure

• unlawful destruction or accidental loss

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All of our employees, directors, Club representatives and data processors including third parties (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with, the processing of personal information, are obliged to respect the confidentiality of the personal information of all visitors to the site and all users of our services.  We have appropriate contracts in place. 

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Change of Purpose

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We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  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 where this is required or permitted by law.

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How to access your information and your other rights?

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You have the following rights in relation to the personal information we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.

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Your right of access

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If you ask us, we’ll confirm whether we’re processing your personal information and, subject to any applicable exemptions, provide you with a copy of that personal information (along with certain other details) within the timescales or extended timescales provided for by the GDPR for complex requests, or where applicable, provide you with an explanation as to why we will not be complying with your request. If you require additional copies, we may need to charge a reasonable fee.

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Your right to rectification

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If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If you are entitled to rectification and if we’ve shared your personal information with others, we’ll let them know about the rectification where possible and where this would not involve disproportionate effort. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

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Your right to erasure

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You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it, or if you withdraw your consent (where applicable because that was the legal basis on which we were processing your personal information). If you are entitled to erasure and if we’ve shared your personal information with others, we’ll take reasonable steps to inform those others where possible and where this would not involve disproportionate effort. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

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Your right to restrict processing

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You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as; where the information is inaccurate, or where you object to us holding your information. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

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Your right to data portability

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With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

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Your right to object

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You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or processing your personal information for direct marketing.

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Your rights in relation to automated decision-making and profiling

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You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

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Your right to withdraw consent

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If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

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Your right to lodge a complaint with the supervisory authority

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If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the Information Commissioner’s Office (ICO) in the UK where your concern relates to the International Jaguar XK Club. You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their office on 0303 123 1113.

Or where your concern relates to the International Jaguar XK Club, you can report it to the Data Protection Commissioner. You can find details about how to do this on the Commissioner’s website at https://www.dataprotection.ie/docs/complaints/1592.htm or by calling their office on +353 (0761) 104 800.

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If you want to exercise any of these rights you can do so by contacting us in the first instance.

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Collection of information by third-party sites and sponsors

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This website contains links to other sites whose information practices may be different from ours. Visitors should consult the other sites' privacy notices as the International Jaguar XK Club has no control over information that is submitted to, or collected by, these third parties once you leave our site.

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Changes to this Privacy Policy

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This Privacy Policy is effective from 24th May 2018.  It is reviewed when necessary and at least annually.  Any changes will be published here and you will be notified by email or through the Club magazine.

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To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.

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Glossary

 

Data Controller - means the organisation which is responsible for processing data and ensuring that personal data is processed in accordance with data protection law.

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Legitimate Interest – means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 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).

 

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.

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