Dragonfly Leisure understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
1. Information About Us
Writhlington Trust, trading as Writhlington Leisure a limited company, registered in England and Wales under company number 4757263 and Charity Number 1111515 Registered address: Writhlington Trust, Writhlington Sports Centre, Knobsbury Lane, Writhlington, Radstock.
VAT number: 909 432 912
Telephone number: 01761 252631.
2. What Does This Notice Cover?
This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.
3. What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
The personal data that we use is set out in Part 5, below.
4. What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
5. What Personal Data Do You Collect?
We may collect some or all of the following personal data (this may vary according to your relationship with us:
6. How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for one of the following purposes:
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone and post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
7. How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. We have data retention policies in place to ensure that data is either deleted or anonymised. Some data is anonymised rather than deleted at the end of the retention period for the purposes of statistical analysis to improve the products and services offered. The following data is anonymised:name, address, email address, telephone numbers, health and medical notes, workout notes, messages. This ensures that no personally-identifiable information remains on our systems.
8. How and Where Do You Store or Transfer My Personal Data?
We store your data via google drive for business this is protected as part of the EU-US Privacy Shield. This requires third parties to provide data protection to similar standards of those in Europe. More information is available from the European Commission.
The security of your personal data is important to us and to protect your data, we take a number of important measures, including the following:
9. Do You Share My Personal Data?
We contract with the following third parties to supply products AND/OR services to you on our behalf. In some cases, those third parties may require access to some or all of your personal data that we hold.
Delta Computer Services – UK based leisure management software provider who is GDPR compliant. Your personal data is collected and stored on a bookings and membership database that they supply. This software is located on a secure server on our premises. Delta Compuer Services may, from time to time, be required to gain remote access to the server, for the purposes of technical support.
The Retention People (TRP) – UK based customer experience management software provider who is GDPR compliant. TRP are a data processor of our fitness member details. We use this software to
Pulse Fitness – UK based fitness equipment and member software provider who is GDPR compliant. We use their cloud-based product called Pulsemove. This is a membership database for the purposes of fitness programme prescription. We use the software to
CoursePro – UK based sports course software management provider who is GDPR compliant. CoursePro are a data processor of our sports course customer details. We use this software to
Other Sports Clubs – Personal information regarding attendees on our sports courses (gymnastics, tennis, trampoline, dance etc) may be shared with other sports clubs / organisations for the purposes of competition or exam entry. Where we do this your express consent will be required for each entry.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10. How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 21 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
11. How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including making a subject access request, please use the following details
For the attention of : Matt Wise, Chief Executive
Telephone number: 01761 252631
Postal Address: Writhlington Leisure, Knobsbury Lane, Writhlington, Radstock BA3 3NQ.
12. Changes to this Privacy Notice
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.