We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation and the Data Protection Act 2018 and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
The information we collect may be collected via our website, telephone, our social media channels, any surveys or questionnaires, our appointed agents, by post or in person from you.
Here are some key terms used in this policy:
|We, us, our:||ClimbWales Ltd|
|Our Data Privacy Manager:||Glyn Davidson|
|Personal information:||Any information relating to an identified or identifiable individual|
|Special category personal information:||Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership. Genetic and biometric data. Data concerning health, sex life or sexual orientation.|
What types of personal information do we collect about you
We may collect and use the following personal information about you:
- When you make a booking with us we will usually collect your name and title, address, e-mail address, telephone number, date of birth, the names of other members of your party, details of next of kin, medical and physical conditions, payment card details, meal preferences and nationality. We need this information in order to customise your event, book the services you are requesting and deliver your specific requirements.
- Where you (or any participant) provides us with special categories of personal information you agree that you have voluntarily provided such information, and you consent (and the participant consents) for us to use that information for the purposes for which it was collected.
- If you contact us online, we may keep a record of your email correspondence.
- If you contact us by telephone, we may record and/or monitor telephone conversations for training and customer services reasons.
- If you enter a competition or complete a survey we will collect your name and relevant contact information.
- If you report a problem with our services we will collect your name and relevant contact information.
- If you make a complaint in connection with our services we will collect your name and relevant contact information.
- Your transaction/payment information (but please note that full debit card and credit card information is not processed by us as it is passed through to a PCI-DSS compliant third-party payment provider in accordance with good industry standard).
- Your image, where it is captured by CCTV or other visual recording equipment.
Personal information we collect and/or observe about you
Based on how you have used our services in the past and your activity on our website and by telephone, we collect the following personal information from you:
- Details of the services we have provided to you in the past, including your previous event arrangements.
- Details of your visits to our website, and of the resources that you access. We may use visitor information to measure the entry and exit points of visitors to the website and respective numbers of visitors to various pages and sections of the website and details of searches performed. We may also use this information in the future to measure the usage of advertising banners, and other "click throughs" to and from the website. We have security processes in place to ensure that your personal information is held on a central database and is not accessible by any unauthorised persons. However, persons such as IT systems suppliers may need to have access to the system from time to time.
- Details of the website(s) you visited before you use a link to our website, pages visited in our website, and time spent on each. Information about your computer, or mobile device. This is statistical data about our users’ browsing actions.
Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes
We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order.
We also process your personal information for crime prevention and detection purposes.
How your personal information is collected
We collect most of this personal information directly from you—in person, by telephone, by post or email and/or via our website. However, we may also collect information:
- From another person making a booking on your behalf
- From your travel companion
- From our promotion partners
- From social media
- From a third party with your consent
- Via our IT systems, e.g. automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email systems
How and why we use your personal information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract
- For our legitimate interests or those of a third party
- Or, where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
There may be more than one legal basis for us processing your data depending on the specific particular purpose for which we are doing so. Please refer to the 'How to contact us' section of this policy for our contact details if you need details about the specific legal basis upon which we are relying to process your personal data where more than one ground is set out in the table below.
The table below explains what we use (process) your personal information for and our reasons for doing so:
|What we use your personal information for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract. For example, to manage your booking with us, complete your event arrangements and to take payment for your booking.|
|To prevent and detect fraud against you||For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you|
|Conducting checks to identify our customers and verify their identity.
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator.
|To comply with our legal and regulatory obligations|
|Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies.||To comply with our legal and regulatory obligations.|
|Recording calls made to us so we can review how we handle calls and make any necessary improvements.||For our legitimate interests.|
|Provide you with special assistance in relation to special categories of personal information.||For the performance of our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; with your consent.|
|Improve our products and services.||For our legitimate interests.|
|Ensuring business policies are adhered to, e.g. policies covering security and internet use.||For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.|
|Operational reasons, such as improving efficiency, training and quality control.||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.|
|Ensuring the confidentiality of commercially sensitive information.||For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations.|
|Provide you with special assistance in relation to special categories of personal information.||For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. With your consent|
|Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures.||For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price.|
|Preventing unauthorised access and modifications to systems.||For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.|
|Updating customer records.||For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products.|
|Statutory returns.||To comply with our legal and regulatory obligations.|
|Ensuring safe working practices, staff administration and assessments.||To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.|
|Marketing our services to: existing and former customers, third parties who have previously expressed an interest in our services, third parties with whom we have had no previous dealings.||For our legitimate interests or those of a third party; with your consent, i.e. to promote our business to existing and former customers.|
|For debt collection and credit vetting to project our business against financial loss.||For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services.|
|To seek to protect and promote your health and safety and that of our other customers, staff and third parties.||To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party.|
|To seek to detect, investigate, prevent and report crime and anti-social behaviour.||For our legitimate interests or those of a third party, i.e. to detect and prevent crime and anti-social behaviour.|
|To obtain customer reviews. To publish the customer review on our website and/or any other promotional material.||For our legitimate interests or those of a third party, i.e. to provide its services and to improve its services. With your consent, i.e. to inform other customers about the quality of the service or other experiences you choose to share.|
|For resolving complaints dealing with disputes and legal proceedings.||To comply with our legal and regulatory obligations.|
If you have made an enquiry or purchase on our website or by telephone, your personal information may be used by us in the ways the law allows, to contact you by post or electronic means (email or text message) about our services, including exclusive offers, promotions or new services. We will only do this if you did not opt out of such marketing, at the point where we collect your contact details.
If you have not made an enquiry or purchase, we will only send you information and offers by email or text message if you sign up (opt in) to receive such marketing.
We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.
What you need to do if you don’t want to receive our promotional communications
You have the right to opt out of receiving promotional communications at any time. See 'How to contact us' below.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.
Where your personal information is held
Information may be held at our office, third party agencies, service providers, representatives and agents as described above (see above: Who we share your personal information with).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: Transferring your personal information out of the EEA.
How long your personal information will be kept
Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymise it.
How do we treat personal data of children
The services offered by us are not always directed at children under 16 years old, but some specific services are (which are made clear at the time of promotion or booking). For children younger than 18 years old, the use of any of our services is only allowed with the valid consent of a parent or a guardian. In limited cases as part of a reservation, purchase of other event-related services, or in exceptional other circumstances (such as features addressed to families), we may collect and use information of children only as provided by the parent or guardian or with their consent. If we become aware that we process information of a child under 18 years old without the valid consent of a parent or guardian, we reserve the right to delete it.
Transferring your personal information out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.
- Service providers located outside the EEA.
- If you are based outside the EEA.
These transfers are subject to special rules under European and UK data protection law.
These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure.
Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.
If you would like further information please contact our data privacy manager (see 'How to contact us' below).
Your rights in relation to any personal information we hold about you
You have the following rights, which you can exercise free of charge. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances:
|Request access to your personal data||The right to be provided with a copy of your personal information we hold about you. We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. That may include information about your previous booking(s) or other purchases. If someone is acting on your behalf they will need to provide written and signed confirmation from you that you have given your authority to that person/company for them to make the request. We may not provide you with a copy of your personal information if it includes the personal information of other individuals or we have another lawful reason to withhold that information.|
|Request rectification of the personal data we hold about you.||The right to require us to correct any mistakes in your personal information.|
|Request to withdraw consent||Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How and why we use your personal information’, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, please see the section titled “What you need to do if you don’t want to receive our promotional communications’ for further details. If you would like to withdraw your consent to us processing any special categories of personal information, please contact our data privacy manager. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested. If we have to cancel your booking or other purchase as a result, you may incur a cancellation charge. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.|
|Request restriction of processing of your personal information.||The right to require us to restrict processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want to establish the accuracy of the data; (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 information but we need to verify whether we have overriding legitimate grounds to use it.|
|Request the transfer of your personal information to you or to a third party.||The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party. This right only applies to automated information from which you initially provided consent to use or where we used the information to perform a contract with you.|
|To object to processing of your personal information.||The right to object: at any time to your personal information being processed for direct marketing (including profiling). In certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.|
|Request not to be subject to automated individual decision-making.||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to our Data Privacy Manager—see below: 'How to contact us'
- let us have enough information to identify you (e.g. your full name, address and booking reference number, if you were the lead name on the booking or someone else on the booking. If you have not made a booking please provide us with information of how you have communicated with us; for example have you made a holiday enquiry)
- let us have proof of your identity and address; and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal information secure
We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information.
The regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
This privacy notice was published in November 2019.
Changes to this policy are subject to change by us without prior notification to you.
How to contact us
Our contact details are shown below:
- Web: https://climbwales.co.uk/contact/
- Email: firstname.lastname@example.org
- Tel: +44 (0)1248 566 786
Do you need extra help?
If you would like this notice in another format (for example audio, large print, braille) please contact us (see 'How to contact us' above).