For the purposes of the General Data Protection Regulation (“GDPR”) and UK data protection laws, the data controller is Club Towers Limited, Clapham Road, Bedford, MK41 6EL (hereinafter “the Club”)
The types of information we collect
The information that we collect helps us to continually improve the service that we offer at the Club. We may collect the following types of personal data about you:
- Contact and communications information, including your contact details (including email address(es), telephone numbers and postal address(es) and records of communications and interactions we have had with you);
- Other sensitive personal information including your photograph, date of birth, and gender.
- Information about joint members and other family members including children under the age of 18.
- Financial information, including bank or Direct Debit details;
- Information about your attendance at the Club and use of the various facilities.
- Certain other information which you volunteer when making use of your membership benefits (for example, making court bookings, using the creche or summer camps, making use of other Club facilities, or completing surveys).
- Information about your health or medical conditions, where you have volunteered this, for example so that we can cater for you when you attend a Club social or sports event.
- CCTV recordings – we use CCTV in our Club for security reasons, and these recordings are retained for around 30 days.
- Recorded classes as part of our Live Stream service.
Note that we do not knowingly collect personal information about child members under the age of 16 (apart from name and address) without the permission of their parent or guardian. Please do not allow your children to submit personal information to us without your permission. You have the choice about whether to provide an email address or mobile phone number for your children under 16, or whether they set up a “Mywellness” account.
How we collect your information
We may collect your personal data in a few limited ways, namely:
- Directly from you, when you fill in an application for membership, when you make enquiries or a membership application on our website, when you provide information via the Club’s management software or court booking system, or when you interact with us during your time as a member in various other ways (for example, where you enter a competition, renew your membership, sign up for a course or lessons, take part in internal box leagues, set up a MyWellness account);
- Via our automated systems including our Club Management System, our class and court booking software, our web-site, our live stream video service and our CCTV system.
- From someone else who has applied for membership on your behalf (for example a family member or friend who has provided us with your contact details for that purpose);
- From an external body such as the LTA or England Squash (for example, where the LTA passes on your details to us in connection with a complaint or query you have raised about the Club).
How we use your personal data
Many of the details that you provide are stored on the Club Management system provided to us by Legend Club Management Systems (hereinafter “Legend”). Legend holds ISO9001:2015 and ISO27001:2013 certifications which are both externally assessed by BSi.
If you have set up a Mywellness account, then the details you provide will be stored in the Mywellness system administered by Technogym UK Ltd.
Both Legend and Technogym have reported GDPR compliance to us for their systems.
Personal data provided to us will be used for the purposes set out at the time of collection and, where relevant, in accordance with any preferences you express.
More specifically, we will use your personal data for the following purposes:
- Administration of the Club and your membership, including:
- maintaining membership records;
- taking payment of membership fees and maintaining accounting records;
- facilitating the provision to us by third-party service providers organisation of, and participation in, Club events;
- Fulfilment of orders for goods and services, including class bookings, court bookings, PT sessions, swimming lessons and coaching;
- To improve the service that we offer you, detect or prevent fraud and other abuses, prevent and prosecute crime, improve our web-site and other platforms, and enable third parties to carry out technical, logistical, research or other functions on our behalf.
- To carry our research and statistical analysis about activity levels at the Club (e.g. who is attending, when they are attending, and what activities they take part in) to enable us to improve facilities and services at the Club.
- To communicate with you about the Club activities that we think may be of interest to you;
- To administer teams and tournaments – e.g. reporting results, logging results on web-sites, etc.
- To process your job application, if you apply for employment at Club Towers.
- To promote the Club and promote goods and services of closely related third-parties (for example, our treatment room partners, equipment suppliers, external coaching courses) where we think these will be of interest to you;
- Where this is necessary, for our legitimate interests (or the legitimate interests of a third party).
Club Towers Live Streaming Service
We live stream a proportion of our group exercise classes to the members of this service. We will inform you which classes are live streamed so that you can avoid these if you wish. Note that the live streamed classes are not made openly available on the internet and cannot be “downloaded”.
The resultant videos from these classes are stored in the On Demand section of the web-site for 7 days after the class and can be viewed by members of the service only. After 7 days, the videos are removed from the service.
Your marketing preferences
As a member’s Club, it is vital for us to be able to communicate with our members when necessary for the smooth running of the Club. This includes important correspondence such as:
- Records of transactions, such as payment receipts or Direct Debit confirmations (as applicable).
- Membership related mailings such as chasing outstanding balances, fee changes, notices of formal meetings and information about venue closures and holiday opening hours.
- Newsletters informing members about upcoming activities, facility closures, opening hours, upcoming events, health & safety issues, club rules, and similar items.
Therefore, when you sign up as a member of the Club, you are consenting for us to communicate with you on this basis, including us sending you our regular newsletter, which is published every two weeks.
Children: If you are a head member (i.e. you pay the membership fees) and you have any children as part of your membership, you have the option of providing their contact details (email and mobile phone number) to us, in addition to their name. If you choose to provide these, we will include them in any mailings (e.g. newsletters) that we send out to our members. If you choose not to provide them, then they will not be sent these mailings and all communication will come via the head member or a linked adult member.
Non-Members and Ex- Members
If you have provided your personal data to the Club but are not a member (or are no longer a member) you can choose what type of communication you want to receive from us and how you want to receive it.
Non-members (e.g. if you have visited the Club to view but not yet joined) will have the opportunity to choose whether we store your personal data and whether you wish to receive future communications from us.
Ex-members: when they leave, members will have the opportunity to choose whether they wish to continue to receive future communications from us.
We will always respect these choices.
Any queries about what information we hold about you, and how we use this information should be directed to “The Data Controller”:
Telephone: 01234 607111
Post: Towers Health & Racquets Club, Clapham Road, Bedford, MK41 6EL.
Sharing your information with others
We do not ever sell your personal data. We do not share your personal data with third-parties other than as set out below.
Personal data collected and processed by us may be shared with the following third parties, where necessary:
- Our employees and volunteers, for the purposes of administering your membership and giving you access to the membership benefits to which you are entitled.
- Our contractors and suppliers, including class instructors, coaches, the provider of our club management system (Legend), the provider of the MyWellness fitness programme system (Technogym) and any other third parties who would need access to this data in order to carry out their duties for the benefit of the Club and its members.
How long your information is kept
We keep your personal data only for as long as necessary for each purpose we use it. For most membership data, this means we retain it for so long as you have a valid Club membership and for a period of two years after your last interaction with us (for accounting, tax reporting and record-keeping purposes).
Under certain circumstances, by law 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 information we hold about you corrected.
- 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 exercised your right to object to processing (see below).
- 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. You also have the right to object where we are processing your personal data only for direct marketing purposes.
- Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it. You can also withdraw your consent, where this is the basis for our processing your data (without affecting the lawfulness of our previous processing based on consent).
- Request the transfer of your personal data to another party.
Please note that the above rights are not absolute, and we may be entitled to refuse requests where exceptions apply.
Contact and complaints
- by email: firstname.lastname@example.org
- by telephone: 01234 607111
- or by post: Clapham Road, Bedford, MK41 6EL.
If you are not satisfied with how we are processing your personal data, you can make a complaint to the Information Commissioner. You can find out more about your rights under applicable data protection laws from the Information Commissioner’s Office website: www.ico.org.uk.