Privacy Policy
Sandwell Leisure Trust, trading as Kore, respects your personal data and is committed to protecting it.
Here you can find out about the types
of information we collect from you, how we use it, what data we might share
with others, what rights you have and how you can contact us.
This notice describes processing
relating to the information we obtain from you and other visitors and customers
through a variety of different interactions, including when you visit our
websites or social media pages, or contact our team.
We are a ‘Data Controller’ of your
personal information which means we decide what data is collected, for what
purpose and how it is processed. It also means we are responsible for that
processing, which extends to any third parties we use who may process your
information based on our instructions.
We may work with other organisations
in connection with some of the processing activities described in this
statement, such as social media platforms and other partners supporting
products within our group such as Aqua Mayhem.
Where your data is collected and sent
to other organisations for processing that is in both our and their interests,
we will be making decisions together in relation to that processing and will be
‘joint controllers’ with the organisations involved. Under data protection
laws, we will be jointly responsible to you for any processing of that personal
data. Where this is not the case, the other organisation will be separately
responsible to you, and they will set out their responsibilities in their own
privacy statement. We do not sell your personal data to anyone.
There may be occasions where we would
like to offer promotions or market our products and services to you directly,
but you will be given the option to not receive such communications from
us.
What data do we collect?
We collect information about you when
you engage with our website, social media pages or when you contact us
directly. We may also receive data from third party sources, but we only
collect information which is necessary, relevant and adequate for the purpose
you are providing it for.
Some of the information does not
identify you personally but provides us with information about how you use our
services and engage with us. We use this information to improve our services
and make them more useful to you. An example of this is our use of Cookies on
our websites.
For information about how we use
Cookies, please visit the link to our Cookie Policy on our website.
Here you can learn about managing the optional Cookies we use.
We will collect some or all of the
following information depending on the service being accessed:
1. Name and title.
2. Contact details
including Address, phone numbers, email and social media usernames.
3. Date of Birth.
4. Next of Kin / emergency contacts
5. The date and time you
used our services.
6. Website activity,
including the pages you visited on our website, the features you used and how
long you visited us for, your IP address; your rough geographical location or GPS
location (where you have permitted access to this). The internet browser and
devices you are using, cookie, pixels or beacon information (for more
information please see our Cookie Policy), the website address from which you
accessed our website.
7. Details of any correspondence,
communications or transactions between you and us.
8. Where you engage with us in
a business context, we may collect your job title, company contact details
(including email addresses) and company details (some of which we may obtain
from online or public business directories, including social media).
9. Voice recordings of calls
and/or voice messages you may leave when making calls to our telephone support team.
10. Where you act on
behalf of a business, any information we collect as part of
business telemarketing activity.
11. Your social media name and
identification number, any information you post on our social media pages,
posts in which you include a hashtag or mention relating to us and information
regarding your activities on our social media pages generally (for example, the
time and date of your posts and your ‘likes’);
12. Your direct marketing preferences.
13. Details of services
provided by our group companies that you have received or for which you have registered.
You have the option to not provide us
with this information; however, this may mean that you are unable to receive
certain services from us or communicate with us effectively.
The
lawful basis we use your information and data.
here are several ways in which we may
use or process your personal information:
To Perform a Contract
We may use and process your personal
information where this is necessary to perform a contract with you and to
fulfil and complete your orders, purchases and other transactions entered with
us.
Legitimate Interests
We
will process your personal information where it is necessary for us to conduct
activities for which it is in our legitimate interests as a business to do so.
These
include for marketing purposes including analysing and evaluation so that we
can improve our products and services. To respond to any correspondence, fulfil
customer requests and manage complaints, and manage our CCTV cameras, provide
IT support and services including IT security, receive data from third parties
and from the public domain.
Consent
Where you have provided your consent,
we will use and process your information to contact you from time to time about
promotions, events, products, services or information which we think may be of
interest to you; and to share your personal information with companies within
our Group, so that they can contact you with marketing information about their
products and services.
You have the option to withdraw your
consent at any time by contacting us using the details below or by using the
unsubscribe option provided in our marketing communications.
Processing necessary to provide
Customer Support, improve our services and respond to complaints, claims and regulators.
Processing necessary for us to
promote our business, brands, products, and services
We may contact you with marketing
information after you have purchased a product or service from us. We will only
do this in the way in which the law allows, and we will only contact you with
information about our own products and services and that we believe may be of
interest to you. You have the right to object to us sending you this
information at any time.
Legal Obligation and legal claims
We will process your personal
information to comply with our legal or regulatory requirements, such as tax
collection, health-and-safety, and safeguarding and also to defend or take
legal actions.
Were a substantial change in our
terms and conditions, contract or privacy notices takes place we are legally
obliged to inform you of the change.
Vital Interest
Where a person’s life is in danger,
for example, in the case of an accident at the centre, or with a safeguarding
matter, we are permitted to share limited personal information with authorised
individuals to save their life. As you can imagine, we do not need consent or
permission to do this.
Research and service improvement.
We may use your data to analyse,
evaluate and improve our products and services so that we can provide a more
useful and enjoyable customer experience.
With some research we are permitted
to do this without consent as long as we anonymise the data and keep it secure.
In other cases, such as when using cookies, we need your permission.
For example, we use Google Analytics
software to collect information about how you use our website. This includes IP
addresses. We do not store your personal information through Google Analytics
as the data is anonymised before being used for analytics processing and we
will not identify you through analytics information.
Google Analytics processes anonymised
information about the pages you visit on our website, how long you spend on
each page, how you got to the site and what you click on while you’re visiting
the site.
How do we keep your data safe?
We use technical and organisational measures
to safeguard your data and adhere to the UK General Data Protection Regulations
with regards to protecting your data. This includes measures to deal with any
suspected data breaches.
If you suspect any loss, misuse or
unauthorised access to your data, please contact us immediately using the
contact information below.
Links to other websites
This website may provide links to
other websites. This privacy policy does not extend to linked websites. We do
not have responsibility for the content of these websites or how they use and
protect your data. We advise you to read the privacy policy of other websites
prior to using them.
With whom do we share your data?
We never sell your information to
third parties; however, we do work with our group companies and third-party
suppliers who fulfil business activities for us. The companies we may
share data with include:
· Aqua Mayhem - an SLT company.
· Ice Blue – our web design and hosting company.
· ROCC – our IT support company.
· Any other relevant processors?
We must share data with statutory,
investigatory, or legal authorities such as the Police when required to do so
by law, and we also share data with our Local Authority, our professional
advisors such as our legal, financial, health and safety consultant and external
auditors.
If you use them, we will use Social
Media Platforms to communicate with you and to promote our products
and services. We use your personal information when you post content or
otherwise interact with us on our official pages on Facebook, Instagram,
LinkedIn and Twitter and other social media platforms. We may also view
statistical information and reports regarding your interactions with the pages
we administer on those platforms and their content.
We take steps to ensure that any third-party
partners who handle your information comply with data protection legislation
and protect your information just as we do. We only disclose personal
information that is necessary for them to provide the service that they are
undertaking on our behalf.
Transfers outside Europe. There may be some instances where your
information is processed or stored outside of the UK and EU. In those
instances, we will ensure that appropriate safeguards are in place for that
transfer and storage as required by applicable law.
How long do we keep your
data?
We hold your personal information to
give us an opportunity to form a relationship with you, but we do not keep your
personal information in an identifiable format for longer than is necessary.
Typically, we keep membership information for 18months to support claims or
payment enquiries.
There may be occasions where we
retain your data after our relationship ends to establish, bring or defend
legal claims.
Exceptions to this:
• Where
the law requires us to hold your personal information for a longer period or
delete it sooner.
• Where
you have raised a legal claim, complaint or concern regarding a product or
service offered by us, in which case we will retain your information for a
period of 6 years following the date of that complaint or query; or
• Where
you exercise your right to have the information erased (where it applies) and
we do not need to hold it in connection with any of the reasons permitted or
required under the law.
How can you manage the information we
hold about you?
You have the right to:
- Ask
for a copy of the information that we hold about you.
- Correct
and update your information if it is inaccurate or incomplete.
- Withdraw
your consent (where we rely on it).
- Object
to our use of your information.
- Erase
your information or restrict the use of it.
- You have the right not to be
subject to purely automated decisions which includes profiling; however, we do
not envisage that any decisions will be taken about you in this way.
We will always comply with your
request provided there are no continuing lawful reasons to continue to use and
process that information. In order to comply with a request from you in
connection with the exercise of your rights, for example, if you ask us to
erase your information, we will need to retain some details to evidence that we
have actioned your request and maintain a suppression file.
This privacy notice is subject to change.
The contents of this notice may
change from time to time so you may wish to check this page occasionally to
ensure you are still happy to share your information with us. Where possible,
we will also contact you directly to notify you of any substantial changes.
You can exercise the above rights
and/or manage your information by contacting us using the details below:
Post: Sandwell Leisure Trust, Tipton
Sports Academy, Wednesbury Oak Road, Tipton, West Midlands DY4 0BS
Email: info@korewellness.co.uk
Phone: 0300 012 0121
Complaints
If you remain unhappy after speaking
with us, you have the right to lodge a complaint with the ICO, the data
protection authority in the UK. The contact details for the Information
Commissioner’s Office are below:
Post: Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Call: 0303 123 1113
ICO Livechat: launch here
Email: casework@ico.org.uk
