The K-Club respects your privacy and this notice is given pursuant to the data protection legislation from time to time in force in the United Kingdom including the Data Protection Act 1998 or 2018 or any successor legislation and (for so long as and to the extent that the law of the European Union has legal effect in the United Kingdom) the General Data Protection Regulation ((EU) 2016/679) and any other directly applicable European Union regulation relating to privacy (“Data Protection Legislation”).
All capitalised terms in this notice, if undefined herein, are defined in the Data Protection Legislation.
This privacy notice provides you with details of how we collect and process your Personal Data through your use of our site www.k-club.co.uk (also accessed via www.keystone-gb.com), including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.
K-Club is the data controller and we are responsible for your Personal Data (referred to as “we”, “us” or “our” in this privacy notice).
The Data Protection Administrator is responsible for ensuring that this notice is made available to Data Subjects prior to us collecting/processing their Personal Data.
Where no other legal basis applies, the Data Protection Administrator or other associate/member of the K-Club will ensure that this notice is drawn to the attention of Data Subjects and consent shall be obtained.
Our full details are: Keystone Business Improvement Ltd T/A K-Club
Registered in England & Wales, Company No: 04809640
Email address: Amanda.firstname.lastname@example.org
Postal address: K-Club, 3 Wellgreen Close, Hale, Altrincham, Cheshire WA15 8PT
2. WHAT DATA DO WE COLLECT ABOUT YOU?
Personal Data means any information capable of identifying an individual. It does not include anonymised data.
We may process certain types of Personal Data about you as follows:
• Identity Data may include your first name, maiden name, last name, title, business name and gender.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about payments between us and other details of purchases made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at Amanda.email@example.com.
3. HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
• Direct interactions: You may provide data by filling in forms on our site (or otherwise), by communicating with us by post, phone, email or otherwise, including when you:
o order our products or services;
o subscribe to our service or publications;
o request resources or marketing be sent to you;
o enter a survey; or
o give us feedback.
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookies policy for further details.
• Third parties or publicly available sources: We may receive Personal Data about you from various third parties and public sources such as Technical Data from analytics and search information providers such as Google based outside the EU, plus Identity and Contact Data from publicly availably sources such as Companies House based inside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your Personal Data when legally permitted. The Personal Data we collect will be used for the following purposes:
• Marketing to existing members, event attendees and to those showing an interest in our offerings through submission of a contact form.
• Fulfilling our contractual obligations with our staff, members, customers and suppliers.
• Where we need to comply with a legal or regulatory obligation.
By participating in K-Club events and associated activity you acknowledge we will process your Personal Data pursuant to this notice specifically for the purposes identified herein. We will however always take steps to ensure your express consent is obtained where required.
You may withdraw consent at any time by following the unsubscribe process on our emails or by emailing Amanda.firstname.lastname@example.org.
We may process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at Amanda.email@example.com if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out below.
Purpose/Activity: To register you as a new customer or member of K-Club
Personal Data Type: (a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing & Communications.
Lawful Basis for processing: (a) Performance of a contract with you. (b) Necessary for our legitimate interests to recover debts owed to us. (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Personal Data Type: (a) Identity, (b) Contact, (c) Profile, (d) Marketing & Communications.
Lawful Basis for processing: (a) Performance of a contract with you. (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services.
Purpose/Activity: To enable you to partake in a prize draw, competition or complete a survey
Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications
Lawful basis for processing: (a) Performance of a contract with you, (b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
Purpose/Activity: To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of Data: (a) Identity, (b) Contact, (c) Technical
Lawful basis for processing: (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation
Purpose/Activity: To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
Type of Data: (a) Identity, (b) Contact, (c) Profile, (d) Usage, (e) Marketing and Communications, (f) Technical
Lawful basis for processing: Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of Data: (a) Technical, (b) Usage
Lawful basis for processing: Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of Data: (a) Identity, (b) Contact, (c) Technical, (d) Usage, (e) Profile
Lawful basis for processing: Necessary for our legitimate interests to develop our products/services and grow our business
You will receive marketing communications from us if you have:
• requested information from us or purchased goods or services from us; and
• you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at Amanda.firstname.lastname@example.org at any time.
We may process your Personal Data without your knowledge or consent where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your Personal Data with third parties for the purposes set out in Point 4 above but will not do so without first obtaining your consent. These may include service providers who provide IT and system administration services, professional advisers including lawyers, bankers, auditors and insurers, HMRC, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances and third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your Personal Data and to treat it in accordance with the law. We only allow such third parties to process your Personal Data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of Personal Data outside of the EEA unless the transfer meets certain criteria.
Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA. Whenever we transfer your Personal Data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring that we only transfer your Personal Data to countries that European Commission have approved as providing an adequate level of protection for Personal Data, or where we use certain service providers, we may use specific European Commission approved contracts or codes of conduct or certification mechanisms which give Personal Data the same protection it has in Europe; and finally where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, altered, disclosed or accessed without authorisation. We limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know such data. 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.
8. DATA RETENTION
We will process Personal Data for the duration that you are engaged with us, and for no longer than 6 years after the end of this period. We will store your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In some circumstances we may anonymise your Personal Data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your Personal Data which include the right to
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at Amanda.email@example.com. You will not have to pay a fee to access your Personal Data. We try to respond to all legitimate requests within one month, however on occasion it may take us longer if your request is particularly complex or you have made several requests.
If you are unhappy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
10. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.