Prestige Leisure UK Limited Privacy Notice

Who we are

Prestige Leisure UK Limited (we/us) is a company registered in England under company registration number 02698261 and having its registered office address at Suite G1, Hartsbourne House, Delta Gain, Carpenders Park, Watford, England, WD19 5EF. We can be contacted by email at info@prestigeleisure.com.


We do not have a Data Protection Officer.


Definitions

Controller means a person or a legal person which, alone or jointly with others, determines the purposes and means of the processing of Personal Data


Data Subjecta person who is identified by or identifiable from Personal Data


GDPR the General Data Protection Regulation (2016/679), which is available here.


Personal Data means any information relating to an identified or identifiable natural person.


Processor means a person or a legal person which processes Personal Data on behalf of the Controller.

Special Categories of Personal Data Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

Websitewww.prestigeleisure.com


About this document

This Privacy Notice:

-Takes effect from 25 May 2018

-Is directed to all individuals whose Personal Data we process other than our officers, employees, workers and volunteers (but it does apply to candidates for any of these roles)

-Applies to Personal Data collected by whatever means including without limit through our Website

-Sets out information about how we collect Personal Data, the categories of Personal Data we collect, the purpose for which we process Personal Data, the legal basis for processing, our legitimate interests in processing, how we share Personal Data and the rights of Data Subjects whose Personal Data we process

-May be updated from time to time. The latest version is published at: http://www.prestigeleisure.com/privacypolicy.asp. Please check this page for the latest version of our Privacy Notice

On occasion we may also provide more detailed processing information to a Data Subject in a separate privacy notice. Where we do so, that information will prevail over the information in this document in case of conflict.


Our status

We are the Controller in relation to all Personal Data which we collect.


How we collect Personal Data

We collect Personal Data in the following main ways:

-Through the e-commerce facility in our Website

-Through website contact forms and direct emails from people making enquiries with us

-When communicating with clients and suppliers (and their representatives) by telephone, in person or by email

-When making updates to our statutory register of members and register of people with significant control of our company

-When viewing or downloading information available from public sources (such as Companies House)

-Through social media

-Through use of CCTV

-During recruitment processes

-By taking up external references (e.g. worker references or trade references) and undertaking external credit reference checks


Categories of Data Subject

We process Personal Data in relation to the following categories of Data Subject:

-Our customers and representatives of our customers

-Delivery contacts

-Our shareholders and persons exercising significant control over our company

-Business contacts

-Candidates for employment with us (Candidates)

-Suppliers and representatives of our suppliers

-Visitors to our website

- Visitors to our premises


Types of Personal Data we Process

We process the following types of information which are or may be Personal Data:


Candidate Data

Work history, experience, qualifications, job title, information about disabilities and health conditions if this is disclosed by Candidates


Commercial Records Data

Personal Data comprised in records of sales and purchases of goods and services

Contact Data

Names, addresses, email addresses, telephone numbers, facsimile numbers, job title, organisation, excluding Delivery Contact Data

Credit Reference Data

Credit history and rating, trade references

Delivery Contact Data

Names, job title, organisation and delivery address, telephone number

Employer Reference Data

Employer references

Financial Data

Payment card information, bank account and sort code numbers, records of our financial transactions with you

Incident Data

Personal Data (including Contact Data) relating to injuries occurring at our premises involving visitors

Marketing Data

Records of marketing preferences and requests not to process Personal Data for marketing purposes

Shareholder Data

Entries in our register of members and register of people with significant control over our company, Contact Data relating to our shareholders

Surveillance Data

CCTV footage

We process the following Special Categories of Personal Data:

-Incident Data

-Special Categories of Personal Data included in Candidate Data

We do not expect to process Personal Data relating to criminal convictions.


When the provision of Personal Data is a statutory requirement or a requirement necessary to enter into a contract

It is a requirement before entering into any contract with us to provide us with your name, billing address, telephone number and a delivery address for the goods you are purchasing.

If you require credit to be made available, it is a requirement that you fully complete our credit reference form and arrange for trade references to be provided.

If you do not provide us with your Personal Data in the above circumstances, we will be unable to enter into a contract with you.


Purposes and lawful basis of processing

We process or may process Personal Data for the legitimate purposes set out below:

Purpose

Categories of Personal Data affected

To sell our goods and services

Contact Data, Delivery Contact Data, Commercial Records Data, Financial Data

To procure and receive supplies of goods and services

Contact Data, Commercial Records Data

To perform credit checks and make decisions about applications for credit

Contact Data, Credit Reference Data, Commercial Records Data, Financial Data

To comply with legal obligations

Incident Data, Commercial Records Data, Contact Data, Financial Data, Shareholder Data

To investigate and enforce our legal rights

All of the Personal Data we process (other than Special Categories of Personal Data)

To defend legal claims which may be made against us or our officers, employees or workers

All of the Personal Data we process

To carry out administrative activities, including processing returns and refunds, keeping accounting ledgers and tax records, improving our systems and procedures

Contact Data, Delivery Contact Data, Commercial Records Data, Financial Data

To keep records of accidents and injuries at our premises affecting non-workers

Incident Data

To manage accounts and undertake direct marketing

Contact Data, Marketing Data

To complete reorganisations and sales of our assets and undertaking(s)

All of the Personal Data we process

To assist customers and people making enquiries with us by introducing business to suppliers of products and services we do not offer

Contact Data

To keep a record of your consent or request not to receive marketing communications

Contact Data, Marketing Data

To process payments and refunds

Contact Data, Financial Data

To assess a Candidateís suitability for a position within our business, to manage the recruitment process

Contact Data, Candidate Data, Employer Reference Data

To safeguard our assets and personnel

Surveillance Data

We use Google Analytics and website tools for collecting analytical information about use of our Website. We use settings which mean that online identifiers such as IP addresses are not collected and we do not combine analytical information with other Personal Data we hold to identify or profile you. Google uses information collected through Google Analytics in accordance with its privacy notice available at:

https://policies.google.com/privacy/partners?hl=en-GB&gl=uk

We are not responsible for processing of Personal Data by Google.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact information at the end of this document.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.


Lawful basis for processing

We only process Personal Data where we have a lawful basis for doing so.

Personal Data other than Special Categories of Personal Data

We will process Personal Data where processing is necessary for compliance with a legal obligation. This may apply to Contact Data, Commercial Records Data, Financial Data, Candidate Data and Shareholder Data.

We will process Contact Data, Delivery Contact Data, Commercial Records Data and Financial Data to perform our contracts with you and/or to take steps at your request prior to entering into a contract.

We may request your consent to certain forms of marketing communications and where we do so, consent is the basis upon which we will process your Personal Data for that purpose. We may ask you to consent to other forms of processing from time to time and where we do, consent will be the legal basis for that processing.

Unless we are processing Personal Data on the basis of consent, we rely or also rely upon our legitimate interests which are set out below:


Legitimate Interest

Categories of Personal Data affected

Selling our goods

Contact Data, Delivery Contact Data, Commercial Records Data, Financial Data

Procuring and receiving supplies of goods and services

Contact Data, Commercial Records Data

Performing credit checks and making decisions about applications for credit

Contact Data, Credit Reference Data, Commercial Records Data, Financial Data

Investigating and enforcing our legal rights

All of the Personal Data we process (other than Special Categories of Personal Data)

Defending legal claims which may be made against us or our officers, employees or workers

All of the Personal Data we process (other than Special Categories of Personal Data)

Carrying out administrative activities, including processing returns and refunds, keeping accounting ledgers and tax records, improving our systems and procedures

Contact Data, Delivery Contact Data, Commercial Records Data, Financial Data

Managing accounts and undertaking direct marketing

Contact Data, Marketing Data

Ensuring the continuity of our business following a reorganisation or transfer to a successor

All of the Personal Data we process (other than Special Categories of Personal Data)

.

Assisting customers and people making enquiries with us by Introducing business to other suppliers of products and services we do not offer

Contact Data

Keeping a record of your consent or request not to receive marketing communications

Contact Data, Marketing Data

Processing payments and refunds

Contact Data, Financial Data

To ask shareholders to exercise their legal rights in connection with their shareholdings

Shareholder Data

Recruitment

Contact Data, Candidate Data, Employer Reference Data

To safeguard our assets and personnel

Surveillance Data

Special Categories of Personal Data

We will process Special Categories of Personal Data on the following lawful bases:

Lawful basis

Personal Data affected

Processing is necessary to comply with obligations arising under social security law; processing is necessary for our legitimate interest of defending legal claims which may be made against us or our officers, employees or workers

Incident Data

Processing is necessary to comply with obligations arising under employment law; processing is necessary for our legitimate interest of defending legal claims which may be made against us or our officers, employees or workers

Special Categories of Personal Data included within Candidate Data


Retention periods

We will retain your Personal Data only for as long as is necessary to achieve the purposes (or any compatible purposes) for which it is processed. The retention period applying to Personal Data will depend upon the applicable legal and regulatory requirements, which may change over time, and also upon events occurring after the time of collection, such as the occurrence of a legal claim or the exercise of a data subject right (such as the right to request that we do not use your Personal Data for marketing purposes).


Automated Decision making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage that any decisions will be taken about you using solely automated means. We will notify you in writing if this position changes.


Transfers outside of the European Economic Area (EEA)

We transfer or may transfer Personal Data outwith the EEA in the following circumstances:


The transfer is made to a country which has been determined by the European Commission to provide appropriate safeguards for the rights of Data Subjects


The transfer is made to a company or group of companies which have implemented Ďbinding corporate rulesí approved by the relevant regulator



The transfer is made on the basis of standard contractual clauses approved by the European Commission



The transfer is necessary for the performance of our contract with you or is a step preparatory to entering into a contract with you and is taken at your request


The transfer is necessary for the conclusion or performance of a contract with a third party which is in your interest


The transfer is necessary for the establishment, exercise or defence of legal claims



With the explicit consent of the Data Subject


Recipients of Personal Data

We transfer or may transfer Personal Data to the recipients set out below.

Recipient or category of recipient

Categories of Personal Data affected

Our employees, officers and workers

All of the Personal Data we process

Our customers and people making enquiries with us

Contact Data (relating to other suppliers and service providers)

Providers of services to us, including our IT service providers, self-employed consultants, couriers, credit reference agencies, insurers and professional advisers, including solicitors, advocates, insurance brokers, auditors and accountants

All of the Personal Data we process

Courts and tribunals

All of the Personal Data we process

Suppliers of goods and services which we do not offer

Contact Data

Public bodies including keepers of public registers, the health and safety executive, the Information Commissionerís Office, HMRC

Contact Data, Commercial Records Data, Incident Data, Shareholder Data

Law Enforcement Agencies

All of the Personal Data we process

Successors in title to our business(es)

All of the Personal Data we process

Your legal rights

You have the right to:

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent



Complain to the supervisory authority in connection with our processing of your personal data. You can exercise this right by contacting the Information Commissionerís Office at https://ico.org.uk/.


Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

Our websites may contain links to other websites of interest. However, once you have used one of these links to leave our website, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Notice. You should exercise caution and look at the privacy notice applicable to the website in question.


Contact us

If you have any questions about our processing of Personal Data or would like to exercise one of your legal rights, please contact us at info@prestigeleisure.com.

 

Guidance on data protection law is available from the Information Commissionerís Office at https://ico.org.uk/.