Transition Extreme Sports Limited Privacy Policy

Transition Extreme Sports Limited is committed to safeguarding the privacy of our visitors as well as being committed to complying with the Data Protection Act 1998, the General Data Protection Regulation (GDPR) from the 25^thof May 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This policy sets out how we will treat your personal information and informs customers and users about the collection, use and storage of personal information we may collect from our website, social media sites, within the facility and through the various services that we offer.

For the purpose of the Data Protection Act 1998 (the “Act”), the data controller (“we”, “our”, “us”) is Transition Extreme Sports Limited, Links Road, Aberdeen, AB24 5NN.

Why we need your Personal Information – User Access Purposes

We need to collect our users’ information so that we can manage any memberships and passes you choose to purchase and any visits you choose to make to our facility. This use of personal data applies to both members and non-members and is usually restricted to your name, address, date of birth, email address, telephone number(s) and emergency contact details. We may also process your data based on our legitimate business interests for example in order to operate and improve our business. We will use your information to:-

• Ensure safety and competency of user access privileges;
• Record consent and understanding of participation statements;
• Ensure bookings and payments made by you are honoured;
• Record visits and use of any memberships and passes purchased.

If you do not provide us with all of the relevant personal information that we require it may affect our ability to offer access to areas of the facility as well as our ability of offer you the benefits of purchasing memberships and passes.

When you book a place with us to attend a class, event, training course, session etc. we need to collect your personal information in order for us to honour your booking and enable participation in your chosen sport or service.

If you do not provide us with all of the relevant personal information that we require then this may affect our ability to book a place on any given service.

Why we need your Personal Information – Legitimate Purposes

We also process users’ personal information in pursuit of our mission, ‘To use and promote extreme sports, physical activity and play to bring about positive changes in people’ lives’ and legitimate interests in order to:-

• Promote and encourage participation in extreme sports by sending users’ communications and booking information for upcoming competitions and events. Our competitions and events may be filmed or photographed and your personal information may also be used in images captured from our competitions and events for educational, promotional and developmental purposes. We will always try to actively seek consent before using images for promotional or marketing purposes and will never reveal personal information about children when using images;
• Monitor and develop participation in Transition Extreme’s sports and services by monitoring user engagement and participation in the Climbing Wall, Skatepark and Outdoor Ropes course as well as our Youth and Community projects. We do this to understand which promotions, products and services would better encourage participation in these sports and be utilised best with users.
• Respond to and communicate with users regarding customer queries, comments, support needs and complaints, concerns or allegations in relation to using the facilities or activities undertaken at Transition Extreme. For example, we will use your personal information to follow-up and investigate any complaint made by you, to freeze or suspend access or memberships, take disciplinary action etc.
• Monitor visits and ensure everyone who accesses the sports areas of the facility have declared competency, understand the risks when participating in the extreme sports offered and have declared consent of this understanding.

Sensitive Personal Information

When relevant we may need to store sensitive personal data about our users when accessing the facility, such as relevant medical conditions. We do this as a precaution in case of any emergency, accident or incident and to better improve and prepare for lessons, sessions or other services.

Details of your Transactions

We collect data for any transactions you carry out over the phone and in centre when booking any of our sessions or purchasing admission and other products. We do this in order to track your bookings, visits and payments to ensure the ongoing normal daily operations of the organisation.

We process bank card information at the time we take payment. This data is not stored on our systems and is processed on Payment Card Industry Data Security Standard compliant banking systems.

If you make payment via invoice, cheque or other means we keep a record of your account details insofar as it is necessary to receive or make payment. We store these details securely for as long as our statutory obligations stipulate and are only shared with appropriately trained members of staff in order to complete transactions.

How we protect your Information

We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information and sensitive data.

We will store all the personal information you provide on our secure servers and filling systems following strict processes and procedures. Our servers and filing systems are based in the UK and are accessed by our staff for the purposes set out above.

Please be aware that data transmission over the internet is inherently insecure and we cannot guarantee the security of data sent over the internet.

Disclosure of Information

We may be required to disclose information about you to any of our employees, officers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes as set out in this privacy policy.

In addition, we may disclose your personal information:

• To the extent that we are required to do so by law;
• In connection with any legal proceedings or prospective legal proceedings;
• In order to establish, exercise or defend legal rights (including providing information to others for the purposes of fraud prevention and credit risk reduction);
• To the purchaser (or prospective purchaser) of any business or assets which we are (or are contemplating) selling; and
• To any person who we reasonably believe may apply to a court or any other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
• Except as provided in this privacy policy, we will not provide your personal information to third parties.

Such statutory or regulatory authorities and organizations we may disclose your information to include but are not limited to the Health & Safety Executive, Disclosure Scotland and Police Scotland for purposes such as the safeguarding of children and vulnerable adults.

We may also share personal information with our professional and legal advisors for the purposes of taking advice when relevant.

Transition Extreme Sports Limited employs third party suppliers such as IT consultants, member management systems and analysis professionals. These suppliers may process personal information on our behalf as “processors” and are subject to written contractual conditions to only process that personal information under our instructions and to protect it.

In the event that we do share personal information with external third parties, we will only share such personal information when strictly required for specific purposes. We will take reasonable steps to ensure that recipients shall only process the disclosed personal information in accordance with those purposes.

Retention

We will only keep your personal information for as long as necessary to provide you with the services, products and access privileges you agree to when registering to use the facilities. Unless you ask us not to, we will review and where necessary delete your personal information where you have not visited or renewed consent with us after 3 years.

We will keep certain personal information of users for longer in order to confirm your identity, understand when you made visits to the facility and what products, services and participation you consented to when visiting. We may need to do this in the event of any claims made against Transition Extreme.

Data Relating to Children

Our services are used by people of all ages. We are required to receive and collect personal information related to individuals under the age of 13 when they use the facilities for the purposes outlined above.

Children under the age of 16 years must have a parent or guardian’s clear consent before providing personal information to us and before using any sport areas of the facilities. We do not wish to collect any personal information relating to children without explicit parental consent.

Your Rights

You can exercise any of the following rights by writing to us (see ‘Contact’ section below). Your rights in relation to your personal information are as follows:

• You have the right to request access to the personal information we hold about you by making a “Subject Access Request” (see below);
• If you believe that any of your personal information is inaccurate or incomplete, you have a right to request that we amend or complete your personal information;
• If you wish for us to delete your personal information, you may request that we do so.

Any requests received by Transition Extreme Sports Limited will be considered under applicable data protection legislation by our Data Protection Officer. Any Subject Access Requests or amendments will be dealt with by Transition Extreme’s Data Protection Officer who will confirm identity before any changes are made or before any data is shared.

You have the right to ask us not to process your personal data for marketing purposes by email at any time. We will usually inform you (before collecting your personal data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data.

Access to Information

The Act gives you the right to access information held about you by Transition Extreme Sports Limited. Your right to access can be exercised in accordance with the Act. Provisions of such information will be subject to:

• A Subject Access Request made out to marketing@transition-extreme.comor by post; and
• The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your driving licence, passport or birth certificate certified by a solicitor or bank alongside an original copy of a utility bill showing your current address).

If you would like more detail on our organisational data protection and data security policies and procedures please get in touch to request these via the contact section below.

Changes to our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on our website and, where appropriate, notified to you by e-mail.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Transition Extreme Sports Limited, Links Road, Aberdeen AB24 5NN or sent via email to marketing@transition-extreme.com, marked for the attention of the Data Protection Officer.