1. Personal data – Definition

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:
“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who 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”

2. How we collect information about you

Your contact details are collected directly from you, either when you enter your information on our website, call our sales team or during set up and implementation. When you use our website, we may collect technical information including your computer’s IP address.

3. How we use this information

ClubWise will only process (collect, store and use) the information you provide to us in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We are committed to ensuring that the information we collect and use is appropriate for the purposes listed below and to ensure this does not constitute an invasion of your privacy. Moreover, the information you provide is subject to rigorous measures and procedures to minimise the risk of unauthorised access or disclosure

We use your information in the following ways:

a. Service Delivery

We will use your information to provide you with the services defined in our managed services agreement, including:

• • Contacting you in the support of the products and services we supply to you
• • Communication relating to training opportunities and other information to help you make the most of ClubWise

b. Marketing

We may also send you marketing information by e-mail, sms or via ClubWise itself about products and services which we believe may be of interest to you. However, we will only do so with your prior consent and will always provide the ability to review, change your preferences or unsubscribe with immediate effect. You can also your request via e-mail to [email protected].
In addition, we may also use and disclose information in aggregate (so that no individual customers are identified) for ClubWise marketing and strategic development purposes.

Additionally, we may use your personal data to keep you updated about our products and services and send you promotional material about ClubWise and its affiliates and as permitted by applicable law, on behalf of our parent company, affiliates, subsidiaries (collectively, “Affiliates”) and partner companies. Promotional materials may include marketing communications, online surveys, notifications regarding our events and webinars and those of our Affiliates and partners. If you provide a mobile phone number to us, you are explicitly granting us permission to send text messages, recorded messages, and/or use an auto-dialer to contact that number for marketing and promotional purposes, which we may do at our discretion. You may opt-out of our marketing communications at any time.

c. Consent

You consent to being contacted by ClubWise when you complete and return to us an online request form from our website.
You may revoke your consent to the processing of your data at any time by sending an email to [email protected].

4. Your customer data

This Privacy Notice does not apply to our access to or handling of your customer data; the conditions regarding the handling and processing of your customer data is covered by the managed services agreement between you and ClubWise.

5. Can I find out the personal data that ClubWise holds about me?

ClubWise can confirm the details of any personal data we hold about you and how it is processed. You may also ask us to correct or delete personal information we hold about you at any time.

For more information, to request your details or advise us of any changes, please either:

• • Send an email to [email protected].
• • Write to us at: 9127 South Jamaica St, Suite 200, Englewood, CO 80112

6. Information we receive from other sources

Your information may be passed to and processed by all ClubWise group companies, including staff operating outside of the EU. We may occasionally pass your personal data on to third-party service providers (such as e-mail providers and credit reference agencies) contracted to ClubWise as part of our service provision. Any third parties with whom we share your data are obliged to keep your details secure, and to use them only to fulfil the service they provide to us on your behalf. When they no longer need your data to fulfil these services, they will dispose of the details in line with ClubWise own policies and procedures.
We will never pass your personal information to anyone else, except where we are required or permitted to do so by law (such as information needed for income tax and audit purposes), for any successors in title to our business and suppliers that process information on our behalf both in the UK and abroad.

7. Other web sites

Our web site may contain links to other web sites which are outside our control and are not covered by this Privacy Notice. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy notice, which may differ from ours.

8. Retention

ClubWise will retain your data for as long as we do business with you. On termination of our contract, ClubWise will archive your database no more than 4 weeks after the termination date. Your data will then be archived for a further 3 months for reference and to enable data transfer to another provider should that be required. Following the archive period, your data will then be permanently deleted from our systems.

9. Your rights as a data subject

At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• a) Right of access – you have the right to request a copy of the information that we hold about you.
• b) Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• c) Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• d) Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• e) Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• f) Right to object – you have the right to object to certain types of processing such as direct marketing.
• g) Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.
• h) The right to be notified – If a data breach occurs which compromises your personal data, you have a right to be informed within 72 hours of us first becoming aware of the breach.

Note that if ClubWise refuses a request from you under rights of access, we will provide you with a reason as to why. ClubWise reserves the right to charge a fee in the event of complex, vexatoire and/or repetitive access requests.

Finally, if a data breach occurs which compromises your personal data, you have a right to be informed within 72 hours of us first becoming aware of the breach.

10. The Right to Complain

You have the right to complain to the Information Commissioners Office (ICO) if you have any concerns in the way that ClubWise is handling your data. Please visit www.ico.org.uk for more information.