Privacy Policy

Kings Active Foundation’s Privacy Promise:

We’re committed to protecting the privacy of our customers and users and believe in being upfront about how we collect and process data.

That’s why, alongside our Privacy Policy, we’ve created our Privacy Promise. This quick and simple guide explains how we manage, share and look after your information in simple terms, so you can make informed choices about the data you share.

Our Privacy Promise:
We promise to collect, process, store and share your data safely and securely:

You’re always in control: Your privacy will be respected at all times and we put you in control of your privacy with easy-to-use tools and clear choices.

We work transparently: We will be transparent about the data we collect and how we use that data so that you can make fully informed choices and decisions.

We operate securely: We promise to protect the data you share with us by using appropriate security measures and controls. We’re also careful with who we allow to process your data on our behalf.

For your benefit: We promise that, when we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.

If you’d like to know more, read our full Privacy Policy below.

Privacy Policy:
This Privacy Policy will become effective from the 25^th May 2018.

Our privacy policy will help you understand what information “Kings Active Foundation” collects, how we use it and what choices you have.

WHO WE ARE
Who are “Kings Active Foundation”?
“Kings Camps”, “Kings Recruit”, “Kings Active”, “Birkenhead School Holiday Activity Weeks” and “Kings Volunteer” (referred to in this policy as “we”, “us” or “our”) are trading names of:

Kings Active Foundation
Osborne House
47 Snaithing Lane
Sheffield
S10 3LF

Registered Charity Number: 1105460/SC043119
Registered Company Number: 05099069
ICO Registration Number: ZA113078

and;

Kings Active Foundation Professional Services Limited

Osborne House
47 Snaithing Lane
Sheffield
S10 3LF

Registered Company Number: 03145498
ICO Registration Number: ZA254957

Our Data Protection Team
“Kings Active Foundation” has appointed a Data Protection Officer. They can be contacted in the following ways should you have any questions, complaints or feedback about your privacy:

Email: data.protection@kingsactive.org
Mail: Data Protection Officer

Kings Active Foundation
Osborne House
47 Snaithing Lane
Sheffield
S10 3LF

WHAT PERSONAL DATA WE COLLECT AND HOW WE USE IT

What data we need and why we need it:
This section tells you what personal data we may collect from you, why we need it when you use our services and what other personal data we may receive from other sources.

Date of Birth is required to ensure we are adhering to minimum age requirements. (Children must be 5 years old to attend camp. Staff must be 18 to be contracted to work for us)

We collect data you provide to us:

When you book your child on a camp
When you speak to us over the phone or via email
When you use the contact forms on our website
When you use the Live Chat function on our website
When you apply for a job on the Kings Camps and Kings Recruit website
When you get in touch on the Kings Active website
When you apply for a Base Pack on the Kings Volunteer website
When you apply for a job with us (we collect data when you use our services):
Payment and transaction data – we use SagePay and Paypal for transactions
Profile and usage data, including data we gather from the devices you use to connect to those services such as computers and mobile phones, using cookies (please see our separate cookies policy) and other internet tracking software

We collect data from third parties we work with:

Social networks
Public information sources
Agents working on our behalf

Data we collect about you
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity data – name, title, date of birth, gender, nationality and school details of those buying or using our services. For military staff, we also ask for service number, rank and place of work.

Contact data – location, postcode, email address or telephone numbers.

Transaction data – details of the products and services you have purchased from us, including date and time of booking and spend in relation to that transaction. We also collect the name on your payment card, your card, expiry date and CVV number.

Technical data – internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Profile data – purchases or orders made by you, your interests, preferences, feedback and survey responses, preferences about the use of the services (including whether you are interested in certain events that we offer)

Usage data – information about how you use our website and services.

Marketing and communications data – your preferences in receiving marketing from us and your communication preferences.

Employment information – Previous employment history, experience, relevant qualifications, work eligibility and references.

Criminal conviction and offence information – In order to work for us, you will be required to undertake an enhanced Disclosure check. We use a third party for ID checks and eligibility to work in the UK checks

Health and Medical Information – We will collect any relevant medical or health information of children that attend our camps, including first aid preferences. We also collate medical information, where supplied, for staff applying for select roles and employees.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you, outside of those stated above. This includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

How we use your personal information
We are only allowed to use personal information about you if we have a legal basis to do so, and we are required to tell you what that legal basis is. We have set out in the table below: the personal information which we collect from you, how we use it, and the legal ground on which we rely when we use the personal information.

In some circumstances we can use your personal information if it is in our legitimate interest to do so, provided that we have told you what that legitimate interest is. A legitimate interest is when we have a business or commercial reason to use your information which, when balanced against your rights, is justifiable. If we are relying on our legitimate interests, we have set that out in the table below.

What we use your personal information for	What personal information we collect	Our legal grounds for processing	Our legitimate interests (if applicable)
To register you as a new customer	· Identity · Contact · Health & medical information	· Performance of a contract with you
To process and deliver your booking/purchase	· Identity · Contact · Transaction	· Performance of a contract with you · Legitimate interests
To manage our relationship with you, including notifying you about changes to our terms or privacy notices	· Identity · Contact · Transaction	· Performance of a contract with you · Necessary to comply with a legal obligation (such as minimum age requirements) · Legitimate interests	To keep our records up to date
To enable you to partake in a prize draw, competition or to complete a survey	· Identity · Contact · Transaction	· Performance of a contract with you · Legitimate interests · Consent	To study how customers use our services and to grow our business
To administer and protect our business and our website	· Transaction · Technical · Usage	· Legitimate interests	Running our business, provision of administration and IT services, network security
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	· Identity · Contact · Marketing and communications · Usage · Profile	· Legitimate interests	To study how customers use our services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences	· Technical · Usage · Profile	· Legitimate interests	To define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy
To carryout a DBS check prior to employment	· Identity · Contact · Criminal Convictions & Offence information	· Performance of a contract	To ensure your eligibility to work for us
To make suggestions and recommendations to you about the services that may be of interest to you	· Identity · Contact · Marketing and communications · Technical · Profile · Usage	· Legitimate interests	To develop our services and grow our business

Processing your data using our Legitimate Interests.
We have a number of lawful reasons that we can use (or ‘process’) your personal data. One of these lawful reasons is called ‘legitimate interests’.

Broadly speaking legitimate interests means that we can process your personal information if:
We have a genuine and legitimate reason and we are not harming any of your rights and interests.

The following are some examples of when and why we would use this approach during our normal course of business:

To improve and enhance our services: When we do process your data, we will use it to benefit you and to make your experience better and to improve our products and services.

Your best interest: Processing your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.

Personalisation: Where the processing enables us to enhance, modify, personalise or otherwise improve our services/communications for the benefit of our customers.

Analytics: To process your personal data for the purposes of customer analysis, assessment, profiling and direct marketing, on a personalised or aggregated basis, to help us with our services and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

Research: To determine the effectiveness of promotional campaigns and advertising and to develop our products, services, systems and relationships with you.

Direct Marketing: We may send postal and email marketing. We will also make sure our postal and email marketing is relevant for you and tailored to your interests. You also have the right to opt-out of receiving this information at any time by contacting us or updating your preferences.

When we process your personal information for our legitimate interests, we will consider and balance any potential impact on you and your rights under data protection and any other relevant law. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Who we share your personal information with
In order to provide you with our services and meet our legal obligations, we only share your data with 3rd parties, in the following circumstances:

To fulfil your order;
To complete or confirm your location or postal address;
To verify your identity and perform DBS checks;
To authorise debit/credit card payments and any other transactions authorised by the supporter or customer;
To manage and maintain the accuracy of your records;
To handle complaints and improve customer service;
To administer marketing on behalf of Kings Active Foundation;
To meet legal obligations, for example, for the purposes of national security, taxation and criminal investigations; and
If Kings Active Foundation is acquired by a third party, in which case personal data held by it, about its customers, will be one of the transferred assets.

We’ll never make your personal data available to anyone outside Kings Active Foundation for them to use for their own marketing purposes without your prior consent.

We may recruit on behalf of third parties (e.g. for Cruise and Resort contracts) and we would only share your data when applying for those specific roles.

Third party links
Our website may include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice or policy of every website you visit.

Transferring your personal information outside the EEA
The EEA is the European Economic Area, which consists of the EU Members States, Iceland, Liechtenstein and Norway. If we transfer your personal information outside the EEA, we have to tell you.

We transfer your data outside of the EEA in very limited circumstances. We have ensured those organisations that we share your data with look after it securely and have appropriate safeguards, as required by GDPR in place. These organisations are:

“Clickatell” (Clickatell Limited, Bank House, 81 St Judes Road, Englefield Green, Surrey, TW20 0DF, UK) – Who provide a customer communication and messaging tool. – Clickatell may transfer your data to the US or South Africa whilst complying with applicable, local data protection measures.

“Facebook” (Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA) – Facebook provide a social media platform. – Facebook provide the following safeguard EU-US Privacy Shield and an appointed EU representative in Ireland (Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland)

“Google” – (Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) – Google provide an analytics service – Google provide the EU-US Privacy Shield safeguard

“LinkedIn” (LinkedIn Corporation, 1000 W.Maude Avenue, Sunnyvale, CA 94085, USA) – LinkedIn provide a social media platform. – LinkedIn provide the EU-US Privacy Shield safeguard

“MailChimp” (The Rocket Science Group LLC, 675 Ponce de Leon Avenue NE, Suite 5000, Atalanta, GA 30308, USA) – Provide our email communication platform – MailChimp provide the EU-US Privacy Shield safeguard

“SnapEngage” (SnapEngage LLC, 1722 14th St., Suite 220, Boulder, CO 80302, USA) – Provide our live chat feature – Snap Engage provide the EU-US Privacy Shield safeguard

“Survey Monkey” (The Rocket Science Group LLC, 675 Ponce de Leon Avenue NE, Suite 5000, Atalanta, GA 30308, USA) – Provide our survey platform – Survey Monkey provide the EU-US Privacy Shield safeguard

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Data 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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator (including the ICO) of a breach where we are legally required to do so.

How long do we keep your personal information?
We will keep your personal information for as long as you are our customer or employee.

Customer
After you stop being an active customer, because you have stopped regularly using our services or buying our products, we may keep your personal information for up to 6 years for one of the following reasons:

- - To respond to any questions or complaints from you;
  - To maintain our records;
  - To comply with laws applicable to us.

After such time, we will securely delete your personal information. If we receive a bounce back from any of the emails that we send to you on a number of occasions, we will delete your personal information in relation to those emails.

Employee
For permanent employees, we keep personnel files for 6 years after an employment contract has ended. This information includes, but is not exclusive to employment contracts, training records and salary information. For temporary staff, we keep relevant records for 2 years.

This excludes members of the Senior Leadership Team, whose details are retained permanently.

Marketing
We may use your personal information to tell you about relevant services and any upcoming offers.

We can only use your personal information to send you marketing messages if we have either your consent or a legitimate interest to do so.

You can ask us to stop sending you marketing messages at any time – you just need to contact us or use the opt-out links on any marketing message sent to you. If you have setup an online account with us, then you can also change your communication preferences at any time.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of purchasing our services or any other transaction between you and us.

Your rights

Right to be Informed
We will always be transparent in the way we use your personal data. You will be fully informed about the processing through relevant privacy notices.

Right to Access
You have a right to request access to the personal data that we hold about you and this should be provided to you, under the General Data Protection Regulation (GDPR), within 30 days. If you would like to request a copy of your personal data, please contact us in writing.

Right to rectification
We want to make sure that the personal data we hold about you is accurate and up to date. If any of your details are incorrect, please let us know and we will amend them.

Right to erasure
You have the right to have your data ‘erased’ in the following situations:

- - Where the personal data is no longer necessary in relation to the purpose for which it was originally collected or processed.
  - When you withdraw consent.
  - When you object to the processing and there is no overriding legitimate interest for continuing the processing.
  - When the personal data was unlawfully processed.
  - When the personal data has to be erased in order to comply with a legal obligation.

If you would like to request erasure of your personal data, please contact us in writing. Please note that each request will be reviewed on a case by case basis and where we have a lawful reason to retain the data, it may not be erased.

Right to restrict processing
You have the right to restrict processing in certain situations such as:

- - Where you contest the accuracy of your personal data, we will restrict the processing until you have verified the accuracy of your personal data.
  - Where you have objected to processing and we are considering whether Kings Active Foundation’s legitimate grounds override your legitimate grounds.
  - When processing is unlawful, and you oppose erasure and request restriction instead.
  - Where Kings Active Foundation no longer need the personal data, but you require the data to establish, exercise or defend a legal claim.

The right to data portability
You have the right to data portability in certain situations. You have the right to obtain and reuse your personal data for your own purposes via a machine-readable format, such as a .CSV file. If you would like to request portability of your personal data, please contact us by writing to us this only applies:

- - To personal data that you have provided to us;
  - Where the processing is based on your consent or for the performance of a contract; and
  - When processing is carried out by automated means.

The right to object
You have the right to object to Kings Active Foundation processing your data in these circumstances:

- - Where the processing is for direct marketing. Remember you can opt out of email communication at any time via the unsubscribe feature on our emails;
  - Where the processing is based on legitimate interests;
  - Where the processing is for purposes of scientific/historical research and statistics.

The Regulator

- - If you feel that Kings Active Foundation has not upheld your rights, we ask that you contact our Data Protection Officer whose details can be found in point 1 so that we can try and help.
  - If you are not satisfied with our response, or believe we are not processing your data in accordance with the law you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Their details are supplied below:

Address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113
Website: www.ico.org.uk

How to contact us

Address:
Kings Active Foundation
Osborne House
47 Snaithing Lane
Sheffield
S10 3LF

Telephone: 0114 263 2150
Email: data.protection@kingsactive.org

Kings Active Foundation is committed to safeguarding and promoting the welfare of children and young people. Safer recruitment is central to the way we work and all staff and volunteers are expected to share our commitment to safeguarding, always creating an environment where young people feel safe and can thrive.