Team Glow Privacy Policy (as of January 2023)

We are committed to respecting your privacy. This notice is to explain how we may use the personal information we collect before, during, and after your membership with us. This notice applies to you if a member or a trial member of our club. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection, we will be the controller of any of your personal information.

References to we, our, or us in this privacy notice are to the Team Glow.

We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we not required to do so, but we will have overall responsibility for data protection compliance in our organisation. Contact details are set out in the “Contacting us” section at the end of this privacy notice.

1. Personal Information we may collect from you

When you take a membership with us, you may initially provide us with or we may obtain personal information about you, such as information regarding your:

• personal contact details that allow us to contact you directly such as name, title, email addresses, and telephone numbers;
• date of birth;
• gender;
• membership start and end date;
• records of your interactions with us such as telephone conversations, emails, and other correspondence;
• use of and movements through our online portal, passwords, personal identification numbers, IP addresses, user names, and other IT system identifying information;
• records of your attendance at any events hosted by us;
• images in video and/or photographic form and voice recordings;
• details of next of kin, family members, coaches, and emergency contacts;

2. Special categories of personal information

We will not collect any “special categories” of more sensitive personal information regarding you.

3. Where we collect information

We typically collect personal information about our members when you apply to become a member of the club, you register an account with us, or when you purchase any services or products we offer, when you make a query and/or complaint or when you correspond with us by phone, e-mail or in some other way.

If you are providing us with details of emergency contacts, they have a right to know and to be aware of how what personal information we hold about them, how we collect it and how we use and may share that information. Please share this privacy notice with those of them whom you feel are sufficiently mature to understand it. They also have the same rights as set out in the “Your rights in relation to personal information” section below.

4. Uses made of the information

The table below describes the main purposes for which we process your personal information, the categories of your information involved, and our lawful basis for being able to do this.

For some of your personal information, you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information, we are not be able to admit you as a member as we are not able to properly perform our contract with you or comply with legal obligations. For other personal information, you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the “Contacting us” section below.

Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example, we may no longer be able to provide certain member benefits to you.

5. Direct Marketing

We will not use your information for direct marketing purposes, nor pass any personal data on for such purposes.

6. Disclosure of your personal information

We share personal information with the following parties:

• Any party approved by you.
• Other service providers: for example, payment processors, and IT services (including CRM and website services);
• The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
• Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security.

7. Transferring your personal information internationally

The personal information we collect is not transferred to and stored in countries outside of the UK and the European Union.

8. For how long do we keep personal information?

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 2 years after your last contact with us or the end of your membership. Exceptions to this rule are:

• Information that may be relevant to personal injury or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after the event.

It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address. You may be able to update some of the personal information we hold about you through the Team Glow system. Alternatively, you can contact us by using the details set out in the contact section on the website.

9. Your rights in relation to your personal information

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the erasure of your personal information in certain limited circumstances;
• the right to restrict processing of your personal information where certain requirements are met;
• the right to object to the processing of your personal information;
• the right to request that we transfer elements of your data either to you or another service provider; and
• the right to object to certain automated decision-making processes using your personal information.

You should note that some of these rights, for example the right to require us to transfer your data to another service provider or the right to object to automated decision making, may not apply as they have specific requirements and exemptions which apply to them and they may not apply to personal information recorded and stored by us. For example, we do not use automated decision making in relation to your personal data. However, some have no conditions attached, so your right to withdraw consent or object to processing for direct marketing are absolute rights.

Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the contact section below.

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

10. Changes to this notice

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice, we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

11. Contacting Us

In the event of any query or complaint in connection with the information we hold about you, please email DETAILS TO BE INSERTED.