Privacy Policy

Last updated: [DATE]

1. About this privacy policy

Kinross Curling respects your privacy and is committed to protecting your personal information.

This privacy policy explains how we collect, use, store and protect personal information when you:

visit the Kinross Curling website;
create or use a customer account;
make or manage a booking;
book a class, event, coaching session or ice sheet;
make a payment;
purchase or use a season pass, credit or other entitlement;
contact us or submit an enquiry;
subscribe to communications from us; or
otherwise interact with Kinross Curling.

For the purposes of UK data protection law, the data controller is:

Kinross Curling
Green Road
Kinross
KY13 8TU
Telephone: 01577 861821
Email: [PRIVACY/GENERAL EMAIL]

2. Information we collect

Depending upon how you interact with us, we may collect and process:

Identity and contact information, including your name, email address, telephone number and postal address where required.

Account information, including your customer account details, login information and account status. Passwords are not stored in readable form.

Participant information, including information about people for whom you make bookings and, where relevant, their age or date of birth where this is needed to establish eligibility for particular activities or ticket types.

Booking information, including activities, classes, events, facilities, dates and times booked, ticket types, quantities, booking history, cancellations and attendance information.

Payment and financial information, including amounts charged or paid, payment method, payment status, credits, refunds, invoices and transaction references. Card details entered into an online payment service are processed by our payment provider and are not intended to be stored by Kinross Curling.

Membership and entitlement information, including season passes, subscriptions, customer credits, promotional entitlements and their usage.

Communications, including enquiries, booking notes and correspondence with us.

Marketing preferences, including whether you have chosen to receive marketing communications.

Technical information, which may include IP address, browser/device information and information collected through necessary website logs and cookies.

3. How we obtain your information

Most personal information is provided directly by you when you make a booking, create an account, contact us, make a payment or otherwise use our services.

We may also receive information:

from another person making a booking on your behalf;
from a club or organisation with which you are associated;
from records legitimately held by Kinross Curling and migrated into our current systems; or
from service providers where necessary to operate our website, booking and payment services.

Where information is obtained from another source, we will handle it in accordance with applicable data protection law.

4. How we use your information

We may use your personal information to:

create and administer customer accounts;
verify email addresses and account access;
take, administer and amend bookings;
manage class, event and facility capacity;
administer participants and attendance;
calculate prices and eligibility;
process and reconcile payments;
administer refunds and customer credits;
administer season passes and other entitlements;
send booking confirmations, payment requests, cancellation notices and other service communications;
respond to enquiries;
maintain appropriate financial and business records;
operate and secure our website and booking systems;
prevent misuse and investigate technical or security problems;
understand and improve our services; and
send marketing communications where we have an appropriate lawful basis to do so.

5. Our lawful bases for processing

Depending on the circumstances, we process personal information because:

Contract: processing is necessary to provide a booking, account, payment or other service you have requested.

Legal obligation: we need to retain or process certain information to meet legal, taxation, accounting or regulatory obligations.

Legitimate interests: processing is necessary for the legitimate operation, administration, security and improvement of Kinross Curling and its services, provided those interests do not override your rights and interests.

Consent: where required, for example for certain marketing communications or non-essential cookies, we will ask for your consent. You may withdraw consent at any time.

The applicable lawful basis can differ according to the particular information and purpose.

6. Children and participant information

Some Kinross Curling activities are intended for children and young people.

Where a booking is made for another participant, the person making the booking should have appropriate authority to provide that participant's information.

We only request information about participants that is reasonably necessary to administer the activity, establish eligibility or manage the booking.

[KINROSS TO REVIEW WHETHER ANY ADDITIONAL CHILD-SPECIFIC PRIVACY WORDING OR PARENTAL CONSENT PROCESS IS REQUIRED.]

7. Payments

Online payments may be processed by a third-party payment provider such as Stripe.

Payment providers process payment information under their own security and privacy arrangements. Kinross Curling's booking system records information necessary to identify and reconcile a payment, such as its amount, status, date and transaction reference.

We do not intend to store complete payment-card details within the Kinross Curling booking system.

8. Who we share information with

We do not sell personal information.

We may disclose information where reasonably necessary to:

companies providing website, hosting, software or technical services;
payment processors;
email and communications providers;
professional advisers;
accounting or financial service providers;
public authorities, regulators or law-enforcement bodies where legally required; or
other organisations where you have authorised us to do so.

Service providers acting on our behalf are expected to handle personal information securely and only for the purposes for which it has been provided.

[KINROSS TO CONFIRM ACTUAL PROCESSORS/SERVICES USED.]

9. International transfers

Some service providers may process information outside the United Kingdom.

Where personal information is transferred internationally, Kinross Curling will take appropriate steps to ensure that the transfer is made in accordance with applicable UK data protection law.

[KINROSS TO CONFIRM WHETHER ANY PROCESSORS INVOLVE INTERNATIONAL TRANSFERS AND THE APPLICABLE SAFEGUARDS.]

10. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, accounting, operational and regulatory requirements.

Different information may therefore be retained for different periods. For example, financial records may need to be retained for longer than routine website enquiries.

Information that is no longer required will be deleted, anonymised or securely archived in accordance with Kinross Curling's retention procedures.

[KINROSS TO CONFIRM ITS RETENTION SCHEDULE.]

This is one section Kinross should not leave vague indefinitely: the ICO expects a privacy notice to state either actual retention periods or the criteria used to determine them.

11. Security

We use appropriate technical and organisational measures intended to protect personal information against unauthorised access, alteration, disclosure, loss or destruction.

Access to administrative systems is restricted according to user roles and permissions.

No internet-based system can, however, be guaranteed to be completely secure.

12. Your data protection rights

Depending upon the circumstances and the lawful basis on which we process your information, you may have rights including:

the right to obtain a copy of your personal information;
the right to have inaccurate information corrected;
the right to request deletion of information in certain circumstances;
the right to restrict processing in certain circumstances;
the right to object to certain processing;
the right to data portability in certain circumstances; and
the right to withdraw consent where processing is based on consent.

You can exercise your rights by contacting us using the details above.

Not all rights apply in every circumstance, and we may need to retain some information despite a request for deletion where we have a lawful reason to do so.

13. Marketing

Where you have chosen to receive marketing communications, we may contact you with relevant news, activities, events and offers.

You can change your marketing preferences or unsubscribe at any time.

Withdrawing from marketing does not prevent us sending necessary service communications relating to an account, booking or payment.

14. Cookies

Our website may use cookies and similar technologies.

Cookies necessary for the operation, security and functionality of the website may be used without optional consent where permitted by law. Where non-essential cookies are used, appropriate information and consent choices will be provided.

The ICO currently states that website users need to be informed about cookies and that consent is required for cookies that aren't strictly necessary.

15. Links to other websites

Our website may contain links to external websites. Kinross Curling is not responsible for the privacy practices or content of external websites.

16. Changes to this policy

We may update this privacy policy from time to time to reflect changes to our services, systems or legal obligations.

The latest version will be published on our website with the date on which it was last updated.

17. Complaints

If you have concerns about how we use your personal information, please contact Kinross Curling first so that we can investigate.

You also have the right to complain to the UK's data protection regulator, the Information Commissioner's Office.